Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $5,661.85 in gift tax for 1939. The facts have been stipulated. The petitioner had created nine trusts for the benefit of his four children. He transferred to each trust 80 shares of Rayonier Incorporated common stock and 450 shares of Pilgrim Exploration Company common stock. The Commissioner has held that these transfers constituted taxable gifts made in 1939, because they were...
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