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BROWN v. COMMISSIONER

Docket No. 4992-64.

25 T.C.M. 498 (1966)

T.C. Memo. 1966-92

Nellie I. Brown v. Commissioner.

United States Tax Court.

Filed April 28, 1966.

Attorney(s) appearing for the Case

Grant N. Nickerson, 205 Church St., New Haven, Conn., for the petitioner.

Frederick A. Griffen, for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $35,073 in gift tax of the petitioner for 1961 based upon a fair market value of $258,300 for 42 shares of The Brown and Thomas Automobile Company stock instead of the $105,000 value reported in the return. The only issue for decision is the fair market value of the 42 shares given by the petitioner to her son in 1961.

Findings of Fact

The petitioner filed a gift...

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