WHITAKER, Judge.
The plaintiff in 1938 transferred to his three daughters certain property, upon which transfers the Commissioner of Internal Revenue assessed a gift tax, which was paid by plaintiff, and for which he now sues, on the theory that the transfers were not gifts, but were accountings made by him as trustee. This presents the sole question in the case.
Up until the time of her death in 1918 plaintiff's wife had given him from time to time property...
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