Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency in gift tax for the year 1945 in the amount of $675. The issue is whether a gift in trust was a gift of a future interest in property.
Findings of Fact
The petitioner, an individual born in 1885 and residing in Austin, Texas, filed his gift tax return for 1945 with the collector for the first district of Texas.
The only child of petitioner...
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