Memorandum Findings of Fact and Opinion
FISHER, Judge:
This case is the consolidation of two proceedings, in each of which respondent has determined a gift tax deficiency of $346.46 for the year 1955. The sole issue in controversy is whether petitioners have met the burden of proof that certain securities listed in their gift tax returns for 1953 were not in fact donated to a trust established by Lewis D. Causey in 1953.
Findings of Fact
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