Memorandum Findings of Fact and Opinion
OPPER, Judge:
In these consolidated proceedings petitioners challenge respondent's determination of 1932 gift tax deficiencies and delinquency penalties thereon. The taxes and penalties are as follows:
Gift Tax Penalty George Washington, Sr.... $50,405 $12,601.25 Lina Washington.......... 30,875 7,718.75 Louise Washington........ 30...
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