TEHAN, Chief Judge.
On January 30, 1946, the plaintiff taxpayer made gifts of 344 shares of Amercan Lace Paper Company common stock. In a gift tax return filed for that year, he reported these gifts with a valuation of $250 per share being placed upon the stock. The gift tax return was audited by the Commissioner of Internal Revenue, who determined that the fair market value of the common stock was $900 per share, and assessed gift taxes upon the transfer, of $52...
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