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AVERY v. COMMISSIONER

Docket No. 112526.

3 T.C. 963 (1944)

SEWELL L. AVERY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 6, 1944.

Attorney(s) appearing for the Case

Leland K. Neeves, Esq., for the petitioner.

Gerald W. Brooks, Esq., and Frank T. Donahoe, Esq., for the respondent.

The respondent determined a deficiency of $22,258.49 in the gift tax of the petitioner for the year 1940.

The sole issue is the proper valuation of certain shares of the common stock of Montgomery Ward & Co. and United States Gypsum Co. which on December 31, 1940, were transferred as gifts under trust agreements.

FINDINGS OF FACT.

Certain facts were stipulated and as so stipulated are adopted as findings of fact. They are set forth in great detail...

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