Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined a deficiency in petitioner's gift tax for the taxable year 1959 in the amount of $19,248.35. The parties have made certain concessions which will be reflected in a Rule 50 computation. The only issue remaining for decision is whether the interest of third parties under a gift in trust was ascertainable at the time of the gift so that petitioner is entitled to the gift-splitting...
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