OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $2,436 in gift tax for 1943. The only issue for decision is whether the value of a gift made by the decedent in 1943 was $58,000, as returned, or was $63,800, as determined by the Commissioner in arriving at the deficiency. The facts have been stipulated.
Frank Miller Gould died in 1945 and his estate is represented by his executors.
The decedent purchased a diamond...
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