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MOTT v. COMMISSIONER

Docket No. 108611.

1 T.C.M. 356 (1943)

Charles Stewart Mott v. Commissioner.

United States Tax Court.

Entered January 6, 1943.

Attorney(s) appearing for the Case

E. F. Colladay, Esq., 1331 G St., N. W., Washington, D. C., Wilton H. Wallace, Esq., 1331 G St., N. W., Washington, D C., and Roy E. Brownell, Esq., 1427 Union Industrial Bldg., Flint, Mich., for the petitioner. Thomas H. Lewis, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a gift tax deficiency of $150,712.50 for 1939. The petitioner assails the valuation of the gift.

Findings of Fact

Petitioner, an individual, filed his return in the District of Michigan. On December 5, 1939, he transferred by way of gift in trust for his wife and two children, 100,000 shares of common stock of General Motors Corporation, a Delaware corporation. On that day, on...

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