United States Tax Court April 17, 1972, Docket No. 3695-69 (Estate of Dinell v. Commissioner)

Atkins, Judge:

The respondent determined a deficiency in estate tax in the amount of $22,536.83. The primary issue is whether the transfer made by the decedent to 'her two children of a reversionary interest in a trust created by the decedent was made by decedent in contemplation of death with the result that the value of such rever-sionary interest is to be included in her gross estate under the