Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's gift tax liability for 1944 in the amount of $11,386.88. Petitioner filed gift tax returns in connection with the transfer of one-half of his business to his wife, reporting a value of $25,982.11. Respondent determined the value of the gift to be $87,500, predicating this determination of value primarily upon the earnings of the company. By amended petition, petitioner...
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