Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner has determined deficiencies in the petitioner's gift taxes for the years 1945 and 1946 in the respective amounts of $2,925 and $3,918.75.
The question presented is whether the Commissioner erred in valuing at $355 per share certain stock which was the subject of various gifts from the petitioner to members of his family during 1945 and 1946.
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