JOYCE, District Judge.
This is an action to recover overpayment of gift taxes. The facts are stipulated. In 1937 David J. Winton, hereafter referred to as donor, made a gift of $5,110 to plaintiff, his wife. In the same year he created and made gifts to three trusts for the benefit of his minor children. In his gift tax return he claimed and was allowed an exclusion of $5,000 for each of the four gifts under section 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int...
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