Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined a deficiency in petitioners' gift tax for the taxable year 1959 in the amount of $14,692.50. The only issue for decision is the fair market value of 81/3 shares of common stock of The Cookson Company on April 1, 1959, the date the stock was given as a gift to David E. Cookson by his mother, Dorothy Cookson.
Findings of Fact
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