Memorandum Opinion
OPPER, Judge:
The present controversy arises by reason of a deficiency in gift tax for 1937 in the amount of $6,525 determined against petitioner as trustee and transferee of property of the donor. The sole question presented is whether this petitioner is liable for the tax. A further issue as to the underlying tax liability involving the existence of future interests and the consequent disallowance of certain exclusions has apparently...
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