Memorandum Findings of Fact and Opinion
HILL, Judge:
Respondent determined a deficiency in petitioner's gift tax liability for the calendar year 1942 in the amount of $7,813.10. The question is whether a beneficial interest in a trust created by petitioner in favor of his former wife (pursuant to a property settlement agreement contemplating divorce, which agreement was adopted in the Nevada divorce decree) constituted a gift, as respondent contends, or...
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