Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in the gift tax liability of the petitioner for 1946 in the amount of $11,697.83 and a gift tax deficiency of $3,715.42 for 1947. The sole question presented is the value of gifts of interests in real property for the purpose of gift tax.
Findings of Fact
Minnie Janos, the petitioner, resides in Bronx, New York, and filed gift tax returns for the years in question with...
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