Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in gift tax against the petitioner for the year 1963 in the amount of $5,207.73.
The issues raised by the pleadings are whether the remainder interests in a trust created by petitioner on December 20, 1963, were subject to gift splitting under section 2513 of the Internal Revenue Code of 1954, or, in the alternative, whether an increased marital deduction...
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