Memorandum Findings of Fact and Opinion
This proceeding involves gift tax deficiencies of $4,045.02 for 1946 and $4,644.76 for 1947. The sole question involved is the value of shares of stock which petitioner gave his son in those years. Petitioner reported the gifts in his returns at a value of $150.70 per share in 1946 and $150 per share in 1947, while the respondent has determined a value of $250 a share. Some...
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