TaNNENWAld, Judge: Respondent determined gift tax deficiencies for 1961 in Ithe amounts of $125,029.47 and $56,435.30, respectively, for Morris M. Messing (hereinafter referred to as petitioner) in docket No. 5865-65 and Helen F. Messing, deceased, in docket No. 6295-65. After concessions made by petitioners, there remain for our decision the following issues: <p "b511…
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