Respondent determined a deficiency in petitioner's 1948 gift tax of $15,065.12. The issues before us are:
(1) Did petitioner make gifts to 11 grandchildren or 4 children in 1948 so that the first $3,000 of such gifts may be excluded for gift tax purposes?
(2) Should petitioner's gift tax be based on gifts to a trust in 1948 in the amount of $72,000 or $96,000?
FINDINGS OF FACT.
Some of the facts are stipulated and are incorporated herein...
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