Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined deficiencies in Federal gift tax against each petitioner for the taxable quarter ended December 31, 1976, in the amount of $342,658. By amendment to the answer in the instant case, respondent increased the deficiencies determined in the notice of deficiency by $73,229 for each petitioner. The issues presented for decision in the instant case are as follows: (1) Whether the interests...
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