This proceeding involves a determination of gift tax deficiencies for the years 1935 to 1939, inclusive, together with penalties for failure to file gift tax returns. As originally determined by respondent, the deficiencies aggregated $5,106.75 and the penalties $1,276.70. The determination was made on the theory that one-half of the distributions made in each year from a trust to petitioner's daughter, the beneficiary, constituted a taxable gift of petitioner. No other amounts...
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