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SHERR v. COMMISSIONER

Docket No. 27180.

10 T.C.M. 671 (1951)

Ivens Sherr v. Commissioner.

United States Tax Court.

Entered July 16, 1951.

Attorney(s) appearing for the Case

Samuel Silverman, Esq., and David S. Pollock, Esq., 50 E. 42nd St., New York, N. Y., for the petitioner. William E. Murray, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency of $12,236.63 in the gift tax of petitioner for the calendar year 1946.

Several assignments of error were made by petitioner but at the hearing he narrowed the issues to the following items contained in the petition:

"a) The Commissioner has erroneously determined that the value at the date of gift of 9,000 shares of common stock of Fownes Brothers & Co., Inc...

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