McALLISTER, Circuit Judge.
In December, 1935, respondent executed an irrevocable deed of trust to his wife, as trustee, for his two sons. He retained no control over the management, but provided that the amount of income and principal to be distributed to the beneficiaries should rest entirely in the discretion of the trustee. In his gift tax return, respondent deducted two exclusions of $5,000 from the gifts made to his two sons by virtue of the trust — relying...
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