Memorandum Opinion
KÖRNER, Judge:
Respondent determined a deficiency of Federal estate tax against petitioner in the amount of $28,257.61, by notice of deficiency dated June 22, 1984. After concessions, the issue which we must determine is whether the full value of an annuity which was payable to decedent's two children by reason of his death was, under the facts of this case, fully includable in his taxable estate under the provisions of section 2039...
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