Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The Commissioner has determined a deficiency of $1,051.94 in petitioner's gift tax for the year 1950. Petitioner filed a gift tax return with the then collector of internal revenue for the district of Georgia but paid no tax on a certain transfer in trust, which the Commissioner determined accomplished a gift in the amount of $42,310.71, one-half of which, or $21,155.35, was taxable to him.
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