Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in the petitioner's gift tax for the calendar year 1947 in the amount of $239.95. The claimed deficiency results from the respondent's determination that certain gifts in trusts made during the calendar year 1947 by the petitioner to his minor children were gifts of future interests for which no exclusions are allowable under section 1003 of the Internal Revenue Code.
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