The Commissioner has determined a deficiency in gift tax for 1946 in the amount of $11,138.47. The petitioner contests only part of the deficiency. The amount of the gift tax which is in dispute amounts to about $2,000. The issue presents two questions, whether it is necessary to determine the present value at the date of gift of both the donor's retained life interest in a trust and the present value of a charitable remainder in order to obtain the amount of net gifts for...
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