Memorandum Findings of Fact and Opinion
The respondent has determined for the calendar year 1942 a deficiency of $11,079.84 in the gift tax liability of the decedent Andrew H. Blass, and a penalty of $2,769.96 for failure without reasonable cause to file a timely gift tax return. The petitioner denies the alleged gifts and in the alternative contends that if the gifts were made, the respondent erred in determining that the decedent's failure to file a gift tax return...
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