Memorandum Opinion
WELLS, Judge
Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $42,437.00. After concessions, the issues for decision are: (1) whether the proceeds of two group term life insurance policies owned by petitioner's employer are includible in petitioner's gross estate where petitioner retained the right to designate the beneficiary; and (2) if so, the amount to be included...
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