OPINION
RUWE, Judge:
This case is before the Court on petitioner's motion for summary judgment and respondent's cross-motion for summary judgment, filed pursuant to Rule 121. In his notice of deficiency, respondent determined a deficiency of $179,036.50 in the Federal estate tax of the Estate of Annabel Dye Graves (decedent). After concessions by petitioner, the issue for decision is whether a 1927 trust is includable in the gross estate of the decedent...
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