OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $2,424.38 in gift tax for the calendar year 1937. The parties have filed a stipulation which is adopted as the findings of fact.
The petitioner filed a gift tax return for 1937 with the collector of internal revenue for the first district of New Jersey, in which she reported certain gifts to her children, excluded $5,000 on each, and claimed a specific exemption of $40,000...
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