Memorandum Findings of Fact and Opinion
These consolidated proceedings involve deficiencies in gift tax for 1949, as follows:
Docket No. Deficiency 48491........... $1,357.87 48493......... 33.28
The issue is whether the transfers in 1949 of 1,800 shares of the class B common stock of Klempner Bros, Inc., by the petitioner, Emil Klempner, to his wife and sons were absolute gifts or transfers by him to a trust...
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