PIERCE, Judge:
Respondent determined deficiencies in gift tax in respect of the petitioner, for the years 1951 and 1952 in the amounts of $4,331.79 and $27.93, respectively.
The issues for decision are:
(1) Whether, in determining the amount of petitioner's gifts for the year 1951, there should be allowed pursuant to section 1003 (b) of the 1939 Code,
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