Memorandum Findings of Fact and Opinion
In a statutory notice of deficiency mailed July 8, 1966, respondent determined deficiencies in petitioner's Federal gift tax for the years 1945 and 1964 in the respective amounts of $735.10 and $2,404.99, and for the year 1945 determined additions to tax for failing to file a return and for negligence in the respective amounts of $183.78 and $36.76.
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