Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal gift tax for 1970 in the amount of $33,159.62. In this proceeding, petitioner claims an overpayment of Federal gift tax in the amount of $78,140.33, plus interest of $34,316.61, paid for 1970. The principal issue for decision is whether petitioner's execution in 1970 of a trust instrument in which she transferred to a trust her remainder interest...
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