OPINION.
SMITH, Judge:
This proceeding involves a gift tax deficiency of $4,377.80 for 1932. The respondent has determined that petitioner made gifts to her husband of the income for her life, or the right to receive the income for life, of four trusts which her husband had created for the benefit of her and their four children. The facts are stipulated.
Petitioner is a resident of the State of New Jersey and is the wife of Louis A. Cerf,...
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