HAMILTON, Circuit Judge.
This is a proceeding to review a decision of the Board of Tax Appeals, and involves gift taxes of the respondent for the calendar year 1935 in the amount of $714.37.
The questions presented are: Whether the Commissioner, for the first time on this appeal, may raise the issue that the present gift was a future interest in property under Section 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int.Rev.Acts, page 585, and whether the gift...
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