Memorandum Opinion
TURNER, Judge:
The respondent determined deficiencies of $3,565.47 and $100.46 in the petitioner's gift tax for 1938 and 1939, respectively. The only issue presented is whether in determining the petitioner's total net gifts made in preceding years the respondent erred in determining that of certain gifts of corpus and income made in trust in 1935 the gifts of corpus were gifts of future interests and that no exclusions were allowable...
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