Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in gift taxes for the taxable years 1937, 1938, 1939 and 1940, resulting from his determination that certain gifts of interests in annuity contracts made during those years by Capitola A. Perry were gifts of future interests against which no exclusions were allowable. The deficiency for the year 1937 in the amount of $934.29 is determined as against Clara Ream, a donee; and the deficiencies...
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