Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in petitioner's gift tax liability for the calendar year 1947 in the amount of $3,915.
The sole question presented for decision is whether the value of the gift of jewelry was $87,000, as reported, or $104,400 as adjusted by the respondent in determining the deficiency.
Findings of Fact
The facts are stipulated and they are so found.
On March 11, 1948...
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