Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in gift tax against the petitioners for the year 1953, as follows:
Docket No. Petitioner Deficiency 67132 William Hamm, Jr. .................. $313,787.29 67131 Marie H. Hamm (wife of William) .... 212,603.96
Also, in his amended answers to the petitions herein, the respondent asserted claims...
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