OPINION.
LEECH, Judge:
Respondent determined a deficiency in gift tax of petitioner for the year 1938 in the sum of $51,123.66. By amended answer he asks an increase in the deficiency. The issues are (1) whether the payment of $375,000, made by petitioner in 1938 to his wife, was a gift or a transfer for a full and adequate consideration in money or money's worth within the purview of section 503 of the Revenue Act of 1932,
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