CHABOT, Judge:
Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $382,815.89. The other issues in this case having been severed for trial at a later date, the single issue now presented for decision is whether the commuted value of amounts payable to decedent's children under an employment contract between decedent and his employer is includable in decedent's gross estate either —
(1) Under section 2039...
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