JONES, Chief Judge.
On July 31, 1943, George G. G. Peckham, deceased, made a gift of $20,000 to his daughter Phyllis P. Peckham.
It is the Government's contention that said transfer, made without consideration and while G. G. G. Peckham was hopelessly insolvent, was made with intent to defraud and that defendant holds such money in trust for unpaid income tax liability of G. G. G. Peckham for the year of transfer.
G. G. G. Peckham's income tax return...
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