Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent has determined deficiencies of $9,348.25 and $1,907.52 in petitioner's gift tax for the years 1939 and 1940, respectively, which petitioner assails by this proceeding.
The sole controversy relates to the fair market value at the time of the gift of 250 shares of common stock of The Parker Appliance Company. The deficiency for 1940 is entirely dependent upon the value determined for...
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