Respondent determined a deficiency in gift tax of $10,566.68 for the year 1947. By amended answer respondent asks that the deficiency be increased to the amount of $24,313.81.
The questions here present are whether in determining for gift tax purposes the present net value of gifts given to two trusts there may be excluded from the gross value of the gifts (1) the present worth of petitioner-settlor's future income tax payments which are to be paid by the trustee...
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