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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