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RICHARDSON v. COMMISSIONER

Docket No. 95770.

2 T.C.M. 1039 (1943)

H. Smith Richardson v. Commissioner.

United States Tax Court.

Entered November 30, 1943.

Attorney(s) appearing for the Case

Holt S. McKinney, Esq., 122 E. 42nd St., New York, N. Y., for the petitioner. Thomas H. Lewis, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent originally determined a deficiency in petitioner's gift tax for the year 1935 in the sum of $48,918.87. Petitioner alleges that he overpaid his gift tax for that year in the sum of $72,165.43 which he asks to be refunded. Respondent, by amended answer, prayed that the amount of the deficiency be determined in the amount of $109,615.87.

The questions are: (1) What was the value, on December 20, 1935, of the...

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