Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiencies in petitioners' Federal gift taxes:
Quarter Ended Deficiency December 31, 1979 $ 2,049.92 March 31, 1980 10,619.04
At issue is whether the annual gift tax exclusions (totaling $30,000 on each of the gift tax returns filed by petitioners for the calendar quarters in question) should be disallowed...
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