MEMORANDUM OPINION
WOODWARD, District Judge.
In November 1961 Mrs. Linnie R. Garrard conferred with Mr. James Milam, an attorney of Lubbock, Texas, and inquired of him as to the amount of property she could convey to her daughter, Mrs. Juanelle Tubbs, the plaintiff in this case, without being required to pay a gift tax. Mr. Milam told her of the $30,000 lifetime exemption and after further conversation advised her that she could convey an undivided 480-acre...
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