The respondent determined a deficiency of $11,984.04 in the gift tax liability of Ethel K. Childers for the year 1936. Ethel K. Childers died on June 23, 1946, and the executors were duly substituted as the petitioner.
The issues are:
(1) Whether an amendment dated January 10, 1936, to the trust agreement of May 16, 1932, executed by the decedent, served to effect completed gifts in trust, subject to the gift tax;
(2) If so, whether gifts made to the...
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