Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's gift tax liability for the calendar year 1946 in the amount of $955.37. The only issue is whether three transfers to petitioner's grandchildren were gifts of future interests, with the result that petitioner would not be entitled to the $3,000 exclusion for each of those gifts under Section 1003 (b) (3) of the Internal Revenue Code.
Findings of Fact
Petitioner...
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