GOODRICH, Circuit Judge.
The question in this case is whether the taxpayer is liable for a gift tax for the year 1947. This in turn depends upon whether a gift in trust made by her in 1930 was a final gift in that year or whether its finality was postponed until the later date.
The facts are not difficult. The settlor, then Mrs. Bissell, who was separated from her husband, set up a trust in 1930. Beneficial interest was to herself for life and remainder to...
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