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DAVIS v. COMMISSIONER

Docket Nos. 2383-69, 2384-69.

55 T.C. 416 (1970)

SAMUEL S. DAVIS AND JEANETTE A. DAVIS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 9, 1970.

Attorney(s) appearing for the Case

David A. Johnston, Jr., David C. Stradley, and William R. Thyer, for the petitioner.

Robert A. Roberts, for the respondent.

STERRETT, Judge:

The respondent determined deficiencies in the Federal gift tax of the petitioners as follows:

                                          1964    19652

Samuel S. Davis ----------------------   $4,501   $112
Jeanette A. Davis --------------------    1,619    112

There are essentially two issues for our determination: (1) Whether the respondent erred in disallowing the petitioners...

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