Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in the amount of $68,714.25 in petitioner's gift tax for the calendar year 1939. The sole question presented is whether, and if so, in what value, petitioner's decedent made a taxable gift in 1939 when a trust, established by her in 1926, was terminated eight years earlier than its expiration date, and the corpus distributed to the beneficiaries. The facts, as substantially set out...
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