The Commissioner determined a deficiency of $382.50 in gift tax for 1948. The only issue for decision is whether gifts to trusts for three minor children were gifts of present interests so that the $3,000 exclusions apply.
FINDINGS OF FACT.
The petitioner filed a gift tax return for 1948 with the collector of internal revenue for the fourteenth district of New York.
The petitioner resided in New York City with his wife and their three children, Arthur...
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