L. HAND, Circuit Judge.
This appeal involves a gift tax for the year 1936 upon two trusts set up by the taxpayer on November 30, 1931, before any gift tax had been imposed under §§ 501 and 502 of the Revenue Act of 1932, 26 U.S.C. A. Int.Rev.Acts, page 580, which took effect on June 6th of that year. Each trust was the same except that one was for the taxpayer's daughter, aged eleven, and the other, for his son, aged seven. The property transferred was concededly...
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