Writ of Certiorari Denied March 9, 1953. See 73 S.Ct. 645.
FRANK, Circuit Judge.
The Commissioner determined that the value on the dates of the gifts aggregated $104,400. The taxpayer, who had the burden of proving the error of this figure, failed to discharge it. The sole evidence consisted of the cost to the taxpayer of obtaining the jewelry, in both instances a short time before the gift. He did not show, by introducing an expert's testimony or otherwise...
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