THOMSEN, Senior District Judge.
In this action, tried before the court without a jury, Plaintiff seeks recovery of gift taxes for the years 1971 and 1972 and interest thereon, assessed against her and paid by her to the Government. Plaintiff contends: (1) that gifts in trust of an income interest, made by her in December 1971 and January 1972, constitute a present interest qualifying for the $3,000 per donee exclusion under section 2503(b) of the 1954 Code; and (2...
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