Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioner's gift tax for the year 1946 of $103,645.07. The Commissioner in his deficiency notice explained the deficiency as follows:
"The proposed deficiency results from the following adjustments:
SCHEDULE A Tentatively Returned Determined Item 1 ........... $750,000.00 $879,375.00 Item...
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