Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in gift taxes against petitioners, Frank T. King and Margaret D. King, in the amounts of $247.50 and $67.50, respectively, for the taxable year ending December 31, 1966.
The sole issue is whether the gift of certain property in trust (described herein) constituted a gift of a present interest in property so as to qualify for the exclusionary provisions...
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