OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $1,278.03 in the petitioner's gift tax for 1953. The only issue is whether the petitioner's wife can be regarded as having made one-half of the gifts in question. The facts have been submitted by a stipulation which is adopted as the findings of fact.
Section 1000 (f) (1) (A) of the Internal Revenue Code of 1939 provides that a gift made by a husband or by a wife to a third...
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