Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
This proceeding involves a deficiency in gift tax for the year 1938 in the amount of $2,681.99. The sole issue is whether the decedent made a taxable gift when he, under the circumstances shown in our findings, transferred sundry life insurance policies upon his own life to a corporation, all of the stock of which was owned by him and members of his family or trusts created for his wife and children...
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