L. HAND, Circuit Judge.
This appeal (petition to review) is from an order of the Tax Court, expunging a deficiency assessed by the Commissioner against a donor as a gift tax for the year 1939. The only question involved is the value of the gift. The taxpayer owned more than two-thirds of what were known as "A" shares of stock in a Delaware corporation, known as McCann-Erickson, Inc. These shares had all the voting rights and were cumulatively preferred in dividends...
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