Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in gift tax for the calendar year 1950 against Frances M. and C. H. Cullers in the amounts of $2,185.09 and $4,255.65, respectively, and a penalty of $546.27 against Frances M. Cullers for later filing of her 1950 gift tax return. In his petition C. H. Cullers claimed a refund of $1,922.62.
The principal question presented is the value for gift tax purposes of a farm and cattle...
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