Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in gift tax of $28,264 against the Estate of Jessie M. Small, of which Hugh Matthew Small (brother of Jessie M. Small and hereinafter referred to as petitioner) is the personal representative, as the transferee of assets from her father, Hugh T. Small. The issue for decision is whether Hugh T. Small filed a Federal gift tax return for 1977; if so, the deficiency...
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