Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in petitioner's gift tax of $2,700 for the taxable year 1963.
The only issue for decision is whether petitioner's gifts in trust of rights to receive the income and, under certain circumstances, part of the corpus of an irrevocable trust established by petitioner are gifts of future interests in property which do not qualify for annual exclusions from the gift...
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