The Commissioner determined a deficiency of $23,360.21 in petitioner's gift tax for the calendar year 1947. The deficiency was based on a determination by the Commissioner that the gift of the property involved to petitioner's son and daughter was a gift of future interests, subject to a life estate in the property. The petitioner contends that the transaction constituted a bona fide sale which was a bargain purchase on the part of the children, and that the amount of the...
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