Memorandum Findings of Fact and Opinion
KERN, Judge:
These cases involve deficiencies in Federal gift taxes determined by respondent in the amount of $1,537.50. The sole issue is whether petitioners' liabilities for this tax are barred by the statute of limitation, and this issue depends upon whether petitioners are transferees within the meaning of section 1025 (b), I. R. C. The facts were stipulated and are as follows:
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