HEMPHILL, District Judge.
Plaintiff was assessed a tax deficiency on a gift tax return for 1960. The deficiency was paid; claim for refund was filed; and suit for refund was instituted.
On June 10, 1960, the taxpayer transferred certain stocks and bonds in trust in favor of his three adult children: Robert A. Jolley, Jr., age 39; James E. Jolley, age 33; Mamie Jolley Bruce, the mother of two minor children and the only parent among the beneficiaries. They...
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