OPINION
IRWIN, Judge:
Respondent determined a deficiency in petitioner's estate tax of $28,074.21. Due to concessions, the only issue remaining for our consideration is whether petitioner is entitled to a charitable deduction for the value of the remainder interest of a trust which was bequeathed to qualifying institutions (within the meaning of sec. 2055(a)(2)).
All of the facts have been stipulated, and the stipulation of facts is incorporated...
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