Respondent determined a deficiency in petitioner's gift tax for 1950 in the amount of $21,079.50. The sole issue is whether the value of a remainder interest transferred by petitioner to his adult daughter in a trust, established by him in 1950 pursuant to a decree of divorce, is taxable as a gift.
FINDINGS OF FACT.
Petitioner is an individual who in 1950 resided in Minneapolis, Minnesota. He filed a gift tax return for that year with the collector of internal...
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