Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax of $47,228.68. After concessions by the parties, the sole issue presented for decision is whether certain gifts of Jessie I. Apple to her two children, on December 30 and December 31, 1976, were made in contemplation of death, within the meaning of section 2035, Internal Revenue Code,
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