DECISION
MYRON L. GORDON, District Judge.
A deficiency in gift taxes was assessed against the plaintiffs, who paid the assessment and commenced this action for refund. The case was tried upon a stipulation of facts which had been executed by the parties.
In 1961 the petitioners created a trust for their 12 grandchildren, all of whom were under the age of 21 at the time the trust was created. The trust agreement provided that the income of the trust...
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