Memorandum Opinion
ARUNDELL, Judge:
Respondent determined deficiencies in the gift taxes of petitioner for the years 1949 and 1950 in the respective amounts of $1,216.77 and $590.62. Gift tax returns for those years were filed with the collector of internal revenue for the first district of New York.
A timely petition was filed with this Court in which petitioner alleged that "The Commissioner erroneously determined * * * the gifts in question were...
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