MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined a $73,789 deficiency in petitioner John E. Wall's gift tax for calendar 1992. Respondent also determined a $73,789 deficiency in the 1992 gift tax of Mr. Wall's spouse, petitioner Joanne Wall. Mrs. Wall is a party to these consolidated cases solely because petitioners elected to treat Mrs. Wall as the donor of one-half of the gifts Mr. Wall made during 1992. See sec. 2513.
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