Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner has determined that Leroy Macomber, deceased, made a gift of real property to the petitioner in 1944, and that there is liability for gift tax in 1944 with respect to the gift in the amount of $12,275.49 which was not paid by Leroy Macomber or his estate, and that the petitioner is liable for the gift tax deficiency as donee and as transferee of the property under sections 1009 and 1025...
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