Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This case involves a deficiency in gift taxes for the calendar year 1942 in the amount of $6,480. In his deficiency notice the Commissioner "* * * held that the 500 shares of common stock of the Walker-Smith Company * * * had a fair market value at date of gift [December 25, 1942] of $103,000.00 in lieu of $55,000.00 as reported." The correctness of that holding presents the sole issue in this case....
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