HASTIE, Circuit Judge.
The single issue raised on this appeal is whether the terms and scheme of a trust indenture are such as to enable a valuation of a beneficiary's present interest in the trusted property which will support a claim of the settlor to a gift tax exemption under the familiar statutory exclusion of the first $3,000 given to any person during a taxable year. The Tax Court rejected the claimed exemption.
In 1945, the taxpayer by a single trust...
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