Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $18,378.61 in petitioner's Federal estate tax, as well as an addition to tax of $4,360.49 pursuant to section 6651(a), Internal Revenue Code of 1954. After concessions the only issues in dispute are: (1) whether the decedent possessed at his death a general power of appointment over a portion of the Frank R. Maxant Trust, thus requiring inclusion of such portion...
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