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BRYAN v. COMMISSIONER

Docket No. 23928.

16 T.C. 972 (1951)

ARTIS C. BRYAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 7, 1951.

Attorney(s) appearing for the Case

F. Robert Gilfoil, Jr., Esq., for the petitioner.

Clay C. Holmes, Esq., for the respondent.

This case involves a deficiency in income tax for the year 1944 in the amount of $38,186.25. The issue to be decided is whether certain shares of stock, which were sold by the petitioner in 1944, were a gift to petitioner or whether they had been received by him for adequate consideration. If they were not a gift, a further issue is presented with respect to the basis of the stock for computing gain or loss thereon.

Some of the facts were stipulated.

FINDINGS...

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