Memorandum Opinion
TRAIN, Judge:
Respondent determined a deficiency of $1,620 in the gift tax of the petitioner for the year 1952. The only issue is whether the interests of third parties under a certain gift in trust of which petitioner's spouse is the life beneficiary were "ascertainable at the time of the gift, and hence severable from the interest transferred to his spouse," as provided by Treasury Regulations 108, sec. 86.3a(a)(4), so that petitioner...
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