OPINION.
MURDOCK, Judge.
The Commissioner has determined that the petitioner is liable as a transferee of property of Edward S. Moore for gift taxes for the calendar year 1935 in the amount of $104,864.73, plus interest, on gifts made by Edward S. Moore to this petitioner in 1935. The facts have been stipulated and will be stated herein only to the extent necessary for an understanding of the issues.
Edward S. Moore, the husband of this petitioner...
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