HAYES, District Judge.
R. W. Baker, husband of plaintiff, Penlope Baker, made certain gifts to Wachovia Bank and Trust Co., Winston Salem, N. C., as trustee for various minor grandchildren under certain trust agreements later referred to. They signified their consent to having all of the gifts considered as having been made one-half by the husband and one-half by the wife. On both returns the benefit of the exclusion provided by Section 1003(b) (3) of the Internal...
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