Memorandum Findings of Fact and Opinion
The respondent has determined a deficiency in the petitioner's gift tax liability for the calendar year 1941, in the amount of $134,023.69. The sole question involved is whether the petitioner is subject to gift tax upon a transfer of $500,000, paid in cash, pursuant to an indenture of trust executed on January 25, 1941.
The facts have been stipulated by the parties and are found accordingly. In so far as here material...
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