Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in gift tax of $7,894.23 for the year 1939 against petitioner. The deficiency results from the Commissioner's increasing the value of certain gifts made by petitioner in 1939 to the three of the employees of a corporation of which he was the president and principal stockholder from $35,490.57, as reported on the gift tax return of petitioner, to $116,146,34. The Commissioner explained...
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