Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $24,412.84 in petitioner's Federal estate tax. The sole issue for decision is whether an insurance policy on the life of the decedent was community property of the decedent and his spouse at the time of his death and, therefore, includible in the estate of the decedent to the extent of one half of the proceeds under section 2042(2).
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