DRENNEN, Judge:
The principal issue in these consolidated proceedings is whether the transaction of November 9, 1955, whereby May T. Hrobon, hereinafter referred to as May, purportedly sold her life interest in the Clay M. Thomas trust to Emil M. Hrobon, hereinafter referred to as Emil, for $800,000 payable out of 60 percent of the distributable income of the trust, was in fact a sale of a capital asset by May, as contended by petitioners; or was a gift of...
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