Respondent has determined a deficiency in gift taxes against petitioner as transferee of Marie Elizabeth Moran, alleged donor. The principal issues are whether her acquiescence in three separate trusts constituted taxable gifts by her of interests allegedly owned by her in the principal of each trust, and, if so, whether petitioner may properly be proceeded against as transferee. Another issue is whether the value of any gift held to have been made by her should be held to...
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