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EVANS v. COMMISSIONER

Docket No. 22516.

17 T.C. 206 (1951)

SYLVIA H. EVANS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 13, 1951.

Attorney(s) appearing for the Case

Morse Garwood, Esq., for the petitioner.

Albert J. O'Connor, Esq., for the respondent.

This proceeding involves gift tax deficiencies of $371.56 for 1945, and $1,598.55 for 1946.

FINDINGS OF FACT.

Petitioner is a resident of Philadelphia, Pennsylvania. The returns for the years involved were filed with the collector for the first district of Pennsylvania at Philadelphia.

Part of the facts were stipulated and are so found.

On December 31, 1945, petitioner created a trust for the benefit of her six children. The property transferred...

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