The Commissioner determined a deficiency in petitioner's gift tax for the year 1936 in the amount of $41,736.79 and for the year 1937 in the amount of $8,920.31, by reason of including in petitioner's net gifts for those years amounts representing dividends received by four preferred stockholders of the Wallerstein Co., of which petitioner was a principal common stockholder.
FINDINGS OF FACT.
Petitioner is an individual citizen of the United States, residing...
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