The Commissioner has determined a deficiency of $49,860.57 in petitioner's gift tax for the calendar year 1941. The deficiency is based upon a determination by the Commissioner that petitioner is taxable upon property transferred as a gift in 1941 of the value of $506,931.14, instead of $142,857.01 as reported by petitioner on his gift tax return. The chief item of increase in the amount reported by petitioner was explained in the deficiency notice as follows:
It...
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