OPINION
WELLS, Judge:
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $253,547.77. After concessions, the sole issue for decision is whether proceeds from a life insurance policy, purchased by the insured's spouse within 3 years of the insured's death, are includable in the insured's gross estate where the policy premiums were paid by preauthorized withdrawals from the account of...
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