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supra, 1939-1 C.B. (Part 2) at 476-477; S. Rept. 665,
supra, 1939-1 C.B. (Part 2) at 524. Section 2512(b)
applies "Where property is transferred for less than an
adequate and full consideration in money or money's worth".
If property is so transferred, then section 2512(b)
provides that the excess of the value of the property over
the consideration received "shall be deemed a gift". Thus,
Congress dispensed with the requirement of finding
"donative intent" and made every transfer of property,
other than one in the ordinary course of business, subject
to gift tax to the extent that it is not made for "an
adequate and full consideration in money or money's worth".
Sec. 2512(b); Commissioner v. Wemyss, supra at 306-307;
sec. 25.2512-8, Gift Tax Regs.
Contrary to the premise of petitioner's brief,
subsections (a) and (b) of section 2512 do not prescribe
different methods of valuing property. The value of the
property transferred by gift whether described by section
2512(a) or section 2512(b) is the price at which the
property would change hands between a willing buyer and a
willing seller, neither being under any compulsion to buy
or to sell, and both having reasonable knowledge of
relevant facts. Sec. 25.2512-1, Gift Tax Regs. There is
no authority for the premise of petitioner's brief that
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