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WARNER v. COMMISSIONER OF INTERNAL REVENUE

No. 104, Docket 21991.

193 F.2d 328 (1952)

WARNER v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided January 3, 1952.

Attorney(s) appearing for the Case

Arnold M. Grant, New York City, Wolfe R. Charney, New York City, for petitioner.

Charles Oliphant, Theron Lamar Caudle, Department of Justice, Washington, D. C., S. Dee Hanson, Washington, D. C., Ellis N. Slack, Robert N. Anderson, Special Assts. to the Atty. Gen., for respondent.

Before CHASE, CLARK and FRANK, Circuit Judges.

PER CURIAM.

The sole question presented is whether the fair market value of 15,000 shares of the common stock of Warner Brothers Pictures, Inc., which the petitioner transferred in trust on May 23, 1946 as a gift to one of her daughters and 5000 shares of the same kind of stock which she transferred in the same way as a gift to another daughter was determined by the Tax Court by taking into consideration all of the factors relevant to such a determination.

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