Our examination of the facts and circumstances the exclusive dominion and control of the National Archives. While, in our opinion, the law is clear that an instrument of deed is not a necessary requisite to a gift of personal property, the duly appointed and constituted attorney-in-fact and agent of the taxpayer did on April 21, 1969 execute an instrument of gift reciting and declaring the intent of the donor to make such gift; that said gift had in fact been made on March 27, 1969 and the subject matter thereof delivered to the National Archives. The instrument contained a clause reserving to the donor only a right of access to himself to inspect and copy the materials. In our opinion, the law is clear LAW OFFICES KALMBACH, DEMARCO, ANAPP & CHILLINGWO Coopers and Lybrand that the reservation of such right of access for inspection FDM: gem Very truly yours, KALMBACH, DE MARCO, KNAPP & CHILLINGWORTH By Jack Be Mans. FRANK DE MARCO, JR. Exhibit I-3 BEFORE THE JOINT COMMITTEE ON INTERNAL REVENUE TAXATION MEMORANDUM ON THE BASES SUSTAINING Dated: February 19, 1974 Kenneth W. Gemmill Attorneys for President |