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JUNGBLUTH v. UNITED STATES

No. 15712.

371 F.2d 416 (1966)

Harold J. JUNGBLUTH, Special Administrator of the Estate of John Jungbluth, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Seventh Circuit.

November 30, 1966.

Attorney(s) appearing for the Case

Harry Primakow, Milwaukee, Wis., Erwin Esser Nemmers, Chicago, Ill., for appellant.

James B. Brennan, U. S. Atty., Milwaukee, Wis., Mitchell Rogovin, Asst. Atty. Gen., Jonathan S. Cohen, Atty., Tax Div., Meyer Rothwacks, Gilbert E. Andrews, Attys., Dept. of Justice, Washington, D. C., Franklyn M. Gimbel, Asst. U. S. Atty., of counsel, for appellee.

Before HASTINGS, Chief Judge, and CASTLE and FAIRCHILD, Circuit Judges.

PER CURIAM.

The sole question before us on this appeal is the correct value to be given to certain shares of stock, as of May 15, 1958, for federal gift tax purposes.

On that date, John W. Jungbluth (taxpayer) made a gift of 200 shares of common stock of the R T & E Corporation to his son, Harold, and a like gift of 200 shares to his daughter-in-law, Marion, wife of Harold.

Taxpayer assigned each share of such stock a value of $35, and paid a total...

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