Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioner's gift tax for the year 1946 of $4,027.50. The deficiency is due to one adjustment which the Commissioner has made to the net gifts disclosed on the gift tax return which petitioner filed for the year 1946. That adjustment was: "Add: Stocks — Schedule A of return Item 1 $40,000.00." That adjustment is explained in the deficiency notice as follows:
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