SHARP v. COMMISSIONER

Docket No. 26604.

11 T.C.M. 143 (1952)

Vernon Sharp, Jr. v. Commissioner.

United States Tax Court.

Entered February 19, 1952.


Attorney(s) appearing for the Case

Lawrence B. Howard, Esq., 700 American Trust Bldg., Nashville, Tenn., for the petitioner. Frederick T. Carney, Esq., and S. Earl Heilman, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioner's gift tax for the year 1946 of $4,027.50. The deficiency is due to one adjustment which the Commissioner has made to the net gifts disclosed on the gift tax return which petitioner filed for the year 1946. That adjustment was: "Add: Stocks — Schedule A of return Item 1 $40,000.00." That adjustment is explained in the deficiency notice as follows:

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