GROSS v. COMMISSIONER

Docket No. 5949.

7 T.C. 837 (1946)

WILLIAM H. GROSS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 23, 1946.


Attorney(s) appearing for the Case

Harry J. J. Bellwoar, Jr., Esq., Theodore G. Rich, Esq., for the petitioner.

William H. Best, Jr., Esq., for the respondent.


By this proceeding petitioner seeks a redetermination of a deficiency of $51,818.06 in gift tax for the year 1942. A penalty for delinquent filing of $12,954.52 is also involved. Respondent now concedes the valuation used in arriving at the deficiency to be excessive, and that in the event a taxable gift is found, the amount should be reduced accordingly.

The primary question is whether transfers of partnership interests between members of a family resulted in taxable...

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