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ZORNIGER v. COMMISSIONER

Docket Nos. 3467-70, 3468-70.

62 T.C. 435 (1974)

FRANK E. ZORNIGER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MARY A. ZORNIGER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 27, 1974.

Attorney(s) appearing for the Case

William A. Cromartie, Henry deVos Lawrie, Jr., Samuel H. Horne, and Douglas L. Barnes, for the petitioners.

Nelson E. Shafer, for the respondent.

GOFFE, Judge:

The Commissioner determined deficiencies in gift taxes for the taxable year 1966 against petitioner Frank E. Zorniger (docket No. 3467-70) in the amount of $63,220.05 and against petitioner Mary A. Zorniger (docket No. 3468-70) in the amount of $63,220.05. The issues for decision are: (1) Whether the fair market value for gift tax purposes and for purposes of a "bargain sale" of corporate stock of a Chevrolet dealership is limited to the net fair...

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