The Commissioner has determined deficiencies in gift tax for 1944 and 1945 in the respective amounts of $315.65 and $203.87.
This proceeding has been submitted under the pleadings. There is no dispute about the facts. The question to be decided is whether the petitioner made a gift of a present interest in the income of a trust in each year so as to be entitled to the statutory exclusion allowed by section 1003 (b) (3) of the Code. The respondent has denied the exclusion...
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