These consolidated proceedings involve a proposed deficiency in Federal gift tax for the year 1925 in the amount of $32,348.80, and transferee liability for the same tax. The respondent, upon brief, has conceded that there is no liability on the part of Daisy B. Horst as transferee. The sole question then, is whether the transfer by a husband to his wife of a certain number of shares of stock held as community property, in consideration of a release by her of her community...
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