Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in gift tax of $4,678.20 for 1944 and $288.90 for 1945. The only issue for decision is whether the Commissioner erred in determining that the value of a gift made in 1944 was $55,760 instead of $31,160 as reported on the petitioner's return.
Findings of Fact
The petitioner filed gift tax returns for the taxable years with the collector of internal revenue for the first...
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