Memorandum Opinion
HILL, Judge:
This proceeding involves the redetermination of a gift tax deficiency for the year 1940 in the amount of $520.68. In determining the deficiency, respondent increased petitioner's "gifts made in prior years" by $25,000 by disallowing five $5,000 exclusions taken in connection with five gifts in trust made in 1935. The sole issue is whether such gifts were of future or present interests within the meaning of section 1003 (b...
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