Memorandum Findings of Fact and Opinion
The Commissioner determined a gift tax deficiency of $223.12 for 1950 against each petitioner. The only issue for decision is whether exclusions of $5,250 in each case are allowable under section 1003(b)(3).
Findings of Fact
The petitioners, husband and wife, filed separate gift tax returns for 1950 with the collector of internal revenue for the second district of Texas. Each reported total gifts of $27,000...
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