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GROFF v. SMITH

No. 45.

34 F.Supp. 319 (1940)

GROFF v. SMITH, Collector of Internal Revenue.

District Court, D. Connecticut.

July 12, 1940.

Attorney(s) appearing for the Case

Ralph E. Brush, of Greenwich, Conn., and Leland T. Atherton of New York City (Chadbourne, Hunt, Jaeckel & Brown, of New York City, of counsel), for plaintiff.

Samuel O. Clark, Jr., Asst. Atty. Gen., Andrew D. Sharpe and Carl J. Marold, Sp. Assts. to Atty. Gen., Francis T. Donahoe, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C., and Robert P. Butler, U. S. Atty., of Hartford, Conn., for defendant.

Finding of Facts

HINCKS, District Judge.

A. All the facts of this case are stated in an extensive stipulation which may be deemed a part hereof. I think, however, the following resume will suffice for an understanding of the rulings which I shall presently indicate:

B. 1. The plaintiff on November 11, 1936, gave 14,000 shares of Electrolux Corporation to his wife, and paid a gift tax thereon based on a valuation of $23.375 per share, which was the...

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