This proceeding involves the correctness of the determination of a deficiency in gift taxes for the calendar year 1939 in the amount of $114,893.16. Petitioners, subsequent to filing the petition herein, paid the deficiency on June 23, 1943, and interest on July 21, 1943. They claim an overpayment in the amount of $114,893.16. The issues now are: (1) Whether transfers to a trust by petitioners' decedent in years prior to 1939 during which a gift tax law was in effect were...
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