Memorandum Opinion
LEECH, J.:
Respondent determined a deficiency in gift taxes in the amount of $36,487.85 for the calendar year 1939. The issues presented are: (1) whether the transfers are taxable under the gift tax provisions of the Revenue Act; and (2) whether petitioner is entitled to a specific exemption of $40,000 in determining his gift tax liability.
The case was submitted on a stipulation of facts and exhibits. We find the facts as stipulated...
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