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POWERS v. COMMISSIONER

Docket Nos. 39910 and 39911.

13 T.C.M. 1189 (1954)

T. C. Memo. 1954-239

Estate of Frank T. Powers, Deceased, Frank T. Powers, Jr., et al., Executors, v. Commissioner. Augustin J. Powers v. Commissioner.

United States Tax Court.

Filed December 30, 1954.

Attorney(s) appearing for the Case

Daniel A. Taylor, Esq.* and Robert Lee Henry, Esq., for the petitioners. Joseph F. Lawless, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MURDOCK, Judge:

The Commissioner determined against each petitioner a deficiency of $22,395 in gift taxes for 1941 and a 25 per cent addition, amounting to $5,598.75, for delinquency in filing returns. There are three issues for decisions: (1) whether each petitioner made a gift of one-half instead of one-third of the stock of Powers Photo Engraving Company, (2) what was the value of the gifts, and (3) was the failure...

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