Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined deficiencies in gift tax for the years 1936, 1937 and 1938, in the amounts of $46.29, $46.06, and $46.30. The only question is whether gifts made by petitioner were gifts of future interests for which no exclusions are allowable in computing gift taxes.
Petitioner filed gift tax returns for the taxable years with the collector for the 28th district of New York.
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