Memorandum Findings of Fact and Opinion
This proceeding involves gift tax deficiencies for 1946 and 1947 in the respective amounts of $13,875 and $43,162.50. The only question in issue is the value at the date of the gifts of several pieces of diamond jewelry which petitioner gave to her daughter in 1946 and 1947.
Findings of Fact
Petitioner is a resident of Philadelphia, Pennsylvania. She filed gift tax returns for 1946 and 1947 with the collector...
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