Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $236,260.21 in petitioner's estate tax. The sole issue remaining for our decision is whether the corpus of a trust created by the decedent during her lifetime, and of which she was the sole trustee at the time of her death, is includable in her gross estate under the provisions of section 2036(a)(2) or section 2038(a)(1).
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