Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency in gift tax of the petitioner for the year 1938 in the amount of $13,305.96. In making such determination respondent stated as follows:
Pursuant to an agreement between yourself and Camille Geary to compromise certain litigation, you created a trust on March 21, 1938. While it is conceded that the values of the rights transferred to Camille Geary and to your sons during...
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