STERRETT, Judge:
Respondent, on November 13, 1975, issued statutory notices to the petitioners herein in which he determined deficiencies in their Federal gift tax for the calendar quarter ended December 31, 1972, in the amount of $21,084.28 each. Respondent's motions for leave to file an amendment to his answer and a second amendment to his answer were granted. After concessions by the parties, the sole issue for our determination is whether petitioners are...
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