Memorandum Opinion
OPPER, Judge:
This proceeding was brought for a redetermination of a gift tax deficiency for 1941 in the sum of $2,545.35. By amended answer respondent seeks to increase the amount of the deficiency to $4,418.58.
The questions presented are whether a prior proceeding in the Board of Tax Appeals treating with petitioner's gift tax for the year 1936 precludes respondent from asserting the present deficiency; and whether petitioner...
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