Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in gift tax for the taxable year 1958 of William A. Powe and his wife, Margaret Thomas Powe, in the amounts of $81,668.89 and $82,580.40, respectively. The total deficiency asserted against each petitioner included the deficiency asserted against the other petitioner, the petitioners having signed the consent provided for in section 2513 of the Internal Revenue Code...
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