The respondent determined a deficiency in gift tax for 1946 in the amount of $2,233.19. The issues for decision are: (1) Was the transfer of certain property by petitioner to Charles Burton Orchard, her then husband, a taxable gift; (2) if the transfer is a gift, is the amount of gift tax paid by the donee of the gift pursuant to an oral agreement antedating the gift deductibile in determining the amount of the net taxable gift; (3) is the expense incurred in transferring...
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