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HERZBERG v. COMMISSIONER.

Docket Nos. 3422-70, 3423-70.

30 T.C.M. 1046 (1971)

T.C. Memo. 1971-243

Richard A. Herzberg v. Commissioner. M. Olga Herzberg v. Commissioner.

United States Tax Court.

Filed September 27, 1971.

Attorney(s) appearing for the Case

Martin D. Cohen, Cohen, Rosenbaum & Scher, 744 Broad St., Newark, N. J., for the petitioners. John J. O'Toole, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' gift tax liability:

    Dkt.
    No.       Petitioner         1966      1967

  3422-70  Richard A. Herzberg  $480.68  $3,960.24
  3423-70  M. Olga Herzberg...   844.95   3,553.75

The sole issue is whether certain gifts in trust for the benefit of petitioners' minor daughters meet the requirements of section...

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