Memorandum Opinion
SMITH, Judge:
These proceedings, consolidated for hearing, involve gift tax deficiencies for 1939 and 1940 of $2,637.67 and $3,258.74, respectively. The following questions are presented for decision:
(1) Whether respondent correctly valued gifts consisting of shares of common stock of the Diamond Alkali Company in 1939 and 1940 at the market values of the shares as at the dates of the gifts;
(2) Whether 1939 and 1940 gifts...
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