Memorandum Opinion
OPPER, Judge:
The question upon which the redetermination of a deficiency in petitioner's gift tax for the year 1938 in the amount of $5,135.80 turns, is whether certain interests in income transferred by several trust agreements were present interests entitling petitioner to $5,000 exclusions for each beneficiary or were future interests which under the statute preclude such exclusions.
We find the facts as stipulated. In substance...
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