Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in gift tax as follows:
Quarter Ended Deficiency 12-31-73 .......... $ 165 3-31-74 .......... 3,765 12-31-75 .......... 6,975
The sole issue for decision is whether gifts in trust made to various donees were gifts of a present interest entitling petitioner to section 2503(b)
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