BLACKMUN, Circuit Judge.
The Tax Court has upheld asserted deficiencies in the 1953 federal gift taxes of Marie H. Hamm and William Hamm, Jr., in the respective amounts of $317,281.96 and $456,138.53. Judge Pierce's opinion, 79 pages in length and not reviewed by the full court, is T.C. Memo. 1961-347. Each taxpayer has petitioned for review.
The Hamms are husband and wife and residents of Minnesota. Each filed a timely gift tax return for 1953. By these returns...
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