Memorandum Opinion
TANNENWALD, Chief Judge:
Respondent asserted a deficiency in petitioner's Federal estate tax of $10,411. The sole issue to be decided is whether the value of the proceeds of an insurance policy is includable in the decedent's gross estate where the decedent possessed at the time of death the right to designate the beneficiary of the policy.
This case was submitted fully stipulated pursuant to Rule 122.
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