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WELLER v. COMMISSIONER

Docket Nos. 86488, 86489.

38 T.C. 790 (1962)

CARL E. WELLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. EMILY I. WELLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 10, 1962.

Attorney(s) appearing for the Case

Norman A. Peil, Jr., Esq., for the petitioners.

Max J. Hamburger, Esq., for the respondent.

DRENNEN, Judge:

In these consolidated proceedings, respondent determined deficiencies in gift tax due from petitioner Carl E. Weller (hereafter called Carl) and from petitioner Emily I. Weller (hereafter called Emily) for the year 1955 in the respective amounts of $80,680.17 and $72,481.88.

The issues for decision are:

(1) The value of interests in a limited partnership, Weller Manufacturing Company, transferred by petitioners in 1955 in trust...

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