Memorandum Findings of Fact and Opinion
KERN, Judge:
This proceeding, involving a deficiency in gift taxes for the year 1938, is before this Court under a remand from the Circuit Court of Appeals for the Sixth Circuit [42-2 USTC ¶ 9797, 10,223] for the amendment of the pleadings, for rehearing and the introduction of additional evidence. The question now at issue pursuant to that mandate is whether certain gifts made by the petitioner in 1935, 1936...
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