OPINION.
BLACK, Judge:
This proceeding involves the determination by the respondent of a deficiency in gift tax against Josephine S. Barnard for the calendar year 1943 in the amount of $21,825. After filing her petition with this Court, Josephine S. Barnard died on February 4, 1946. City Bank Farmers Trust Co., a banking corporation duly organized and existing under the laws of the State of New York and having its principal place of business in New...
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