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BELL v. COMMISSIONER OF TAXATION

No. 42646.

188 N.W.2d 827 (1971)

Merton J. BELL, Relator, v. COMMISSIONER OF TAXATION, Respondent.

Supreme Court of Minnesota.

July 2, 1971.

Attorney(s) appearing for the Case

Thompson, Hessian, Fletcher & McKasy, Minneapolis, for relator.

Warren Spannaus, Atty. Gen., Wm. F. Skewes, Sp. Asst. Atty. Gen., St. Paul, for respondent.

Heard before KNUTSON, C. J., and NELSON, OTIS, PETERSON, and KELLY, JJ.

OPINION

PETERSON, Justice.

Writ of certiorari on the relation of Merton J. Bell to review a Tax Court decision affirming the commissioner of taxation's order assessing additional gift taxes against Bell for 1964, 1965, and 1966.

Taxpayer contests the commissioner of taxation's authority to make a second valuation of a gift of stock in a closely held corporation for state gift tax purposes based solely upon a different valuation by

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