FRANK, Circuit Judge.
This is an appeal, by petition for review filed by the Commissioner of Internal Revenue, from a decision of the Board of Tax Appeals, holding that the value of certain remainders created by trusts executed by the respondent was not subject to gift tax for the year 1937. The facts found by the Board may be summarized as follows:
The taxpayer (respondent) established two irrevocable trusts on June 3, 1937, and transferred $10,000 to each...
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