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WEMYSS v. COMMISSIONER

Docket No. 110419.

2 T.C. 876 (1943)

WILLIAM H. WEMYSS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 14, 1943.

Attorney(s) appearing for the Case

Cecil Sims, Esq., and James W. Allen, C. P. A., for the petitioner.

Charles P. Bagley, Esq., for the respondent.

Respondent determined deficiencies in a gift tax in the amount of $12,995.66 for the calendar year 1939 and $3,965.20 for 1940. The issue is whether the transfer on May 24, 1939, by petitioner to his prospective bride of 13,139 shares of common stock of General Shoe Corporation, having a value of $149,456.13, constituted a taxable gift.

FINDINGS OF FACT.

Petitioner is a resident of Davidson County, Tennessee. On January...

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