Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in petitioner's gift tax for the calendar year 1943, in the amount of $347.14, all of which is in controversy.
The sole issue is whether, in computing gift tax liability, respondent erred in disallowing three exclusions totalling $9,000, based on his determination that petitioner's gifts in trust for the benefit of three beneficiaries constituted gifts of "future interests in...
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