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HARVEY v. COMMISSIONER

Docket No. 21835.

11 T.C.M. 773 (1952)

Fred Harvey v. Commissioner.

United States Tax Court.

Entered July 28, 1952.

Attorney(s) appearing for the Case

Llewellyn A. Luce, Esq., 937 Munsey Bldg., Washington, D. C., for the petitioner. S. Earl Heilman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in gift tax against petitioner of $3,045 for the year 1945. The deficiency is due to two adjustments, only one of which is now before the Court. The contested adjustment is due to respondent's increasing the value of the net gifts reported for 1945 from $33,500 to $45,000, which is explained in the deficiency notice as follows:

"It is determined...

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