Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined the following deficiencies in petitioner's gift taxes:
Year Deficiency 1952 ................. $ 268.13 1954 ................. 371.25 1958 ................. 28,701.66 1959 ................. 125,832.57 1960 ................. 28,658.83
Respondent...
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