United States Tax Court.
Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in gift tax for the taxable year 1963 in the amount of $162,792.
The issue presented for decision is whether the transfer by petitioner of real estate to his son and daughter in 1963 constituted a gift and, if so, the amount thereof.
Findings of Fact
Some of the facts were stipulated and are incorporated herein by this reference.
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