Memorandum Findings of Fact and Opinion
KERN, Judge:
In this case respondent has determined that petitioner is liable as donee and transferee for a Federal gift tax for the year 1937 in the amount of $637.49. The sole issue is whether petitioner's liability is barred by the statute of limitations, and this issue depends upon whether petitioner is a transferee within the meaning of section 1025 (b), I. R. C. The parties have stipulated the facts, and we find...
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