Respondent has determined a deficiency in gift taxes of the petitioner for the year 1939 in the sum of $9,775.49, resulting from his including in petitioner's total gifts in that year the amount of $47,316.60 constituting the cost to the petitioner of two annuity contracts in which a former employee of petitioner was named as beneficiary, with refund provisions for the benefit of certain other individuals.
FINDINGS OF FACT.
Petitioner is a resident of Englewood...
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