Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a liability of $600 against each of the petitioners as a "transferee or donee" of John M. Smyth and as representing an unpaid gift tax deficiency of the latter for the year 1937. The question in each proceeding is the same and they are consolidated for hearing.
Findings of Fact
The petitioners are four trusts created on December 30, 1937 by John M. Smyth through...
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