The following excerpt is from Rickenberg v. Commissioner of Internal Revenue, 177 F.2d 114 (9th Cir. 1949):
3 Regulations 108, 86.2, making a similar provision in gift tax cases was held invalid as unwarranted by statute, 26 U. S.C.A. 1000(d), in Mills v. Commissioner, 12 T.C. 468.
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