Memorandum Opinion
RICE, Judge:
This proceeding involves a deficiency in gift tax in the amount of $572.25 determined by the respondent for the year 1950.
The issues are: (1) whether the corpus of a trust which petitioner created for his grandson in 1950 was the gift of a present or future interest to such grandson; and (2) whether the grandson's present right to receive the income of the trust was capable of valuation on the date of the gift.
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