Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated May 29, 1981, respondent determined a deficiency in the Federal estate tax of petitioner-estate in the amount of $47,737.48. Due to concessions by petitioner, the sole issue for decision is whether the decedent, Sylvia H. Roemer, retained, within the meaning of section 2036, I.R.C. 1954, the
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