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KELLY v. COMMISSIONER

Docket No. 19014.

8 T.C.M. 1108 (1949)

Fred T. Kelly v. Commissioner.

United States Tax Court.

Entered December 27, 1949.

Attorney(s) appearing for the Case

James P. Hill, Esq., Atlantic National Bank Bldg., Jacksonville, Fla., for the petitioner. Newman A. Townsend, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in petitioner's gift tax liability for 1944 in the amount of $11,386.88. Petitioner filed gift tax returns in connection with the transfer of one-half of his business to his wife, reporting a value of $25,982.11. Respondent determined the value of the gift to be $87,500, predicating this determination of value primarily upon the earnings of the company. By amended petition, petitioner...

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