OPINION
FEATHERSTON, Judge:
In these consolidated proceedings, respondent determined the following deficiencies in the gift tax of petitioners:
Docket No. Year Deficiency 3236-73 ---------------- 1954 $8,869.65 3237-73 ---------------- 1954 11,441.62
Respondent also determined that additions to the tax were applicable under section 6651(a)
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