Memorandum Findings of Fact and Opinion
ATKINS, J.:
The respondent determined deficiencies in gift tax liability with respect to each of the petitioners for the year 1951 in the amount of $3,600. The sole issue relates to the fair market value of mineral interests transferred by deed of gift on November 1, 1951.
Findings of Fact
The petitioners are husband and wife and reside at Pampa, Texas. In 1951 they owned an 8,000 acre tract of land...
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