OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $34,602.40 in gift tax for 1943. The petitioner alleges that the Commissioner erred in taxing as gifts the 1943 transfers to two trusts which he was required to make by the order of a court. The Commissioner claimed an increased deficiency on the theory that he erroneously omitted from gifts of prior years, in computing the 1943 deficiency, a transfer of securities worth $49,375...
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