Respondent determined a deficiency in gift tax for the year 1948 in the amount of $7,200. The issue is whether petitioner was a resident of the United States for gift tax purposes and therefore entitled to a specific exemption of $30,000 within section 1004 (a) (1), Internal Revenue Code.
FINDINGS OF FACT.
Some of the facts were stipulated by the parties. Those facts are found accordingly and incorporated herein.
The petitioner was born on July 12...
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