Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined deficiencies in gift tax for 1956 in the amount of $926,660.43, and for 1957 in the amount of $53,179.57. Only the gift tax for 1956 is in dispute; the amount of the 1957 tax depends upon the amount of the tax for 1956. The question is the determination of the value, on the date of the transfer, of the contingent remainder interest of petitioner in a testamentary trust created...
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