ST. SURE, District Judge.
Plaintiff made a trust agreement on March 27, 1934, setting up three separate trusts for three of his granddaughters. On August 23, 1935, by amendment, he made these trusts irrevocable. During 1936 he made additional contributions to the trust corpus. In each of his gift tax returns for 1935 and for 1936 he took a total exemption of $15,000, being $5,000 for each beneficiary. Defendant contends that as the three trusts were created by one...
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