Respondent determined gift tax deficiencies for the calendar quarter ending December of 1971 of $998.47 for John H. Vernon and $2,015.36 for Mary E. Vernon. The issue is whether, in valuing the gift in issue, the valuation method contained in section 25.2512-9(a)(1)(i) and (e), Gift Tax Regs., should be used or whether another valuation method is more acceptable.
FINDINGS OF FACT
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