The respondent determined a deficiency in gift tax for the year 1946 in the amount of $11,379.47. The sole issue is whether a transfer of certain property in trust in 1946 effected a taxable gift under section 1000 of the Internal Revenue Code. Respondent agrees that if we find the transfer was a taxable gift, petitioners are entitled to a specific exemption of $30,000 which will be made under a Rule 50 computation, since no adjustment for such exemption was made in computing...
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