OPINION.
WITHEY, Judge:
This is a proceeding for redetermination of a deficiency in gift tax of the petitioner for the calendar year 1947 in the amount of $6,615. The questions for determination are: (a) Were gifts which petitioner made to seven trusts gifts of present or future interests within the meaning of section 1003 (b) (3), Internal Revenue Code, and (b) may exclusions of $39,925 in prior years, now barred by the statute of limitations, if...
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