- 29 -
in the aggregate amount of $970,830. On the other hand, if
the stock is valued as two 25-percent blocks, then the
parties have stipulated that each share of stock was worth
$9,671 immediately before the recapitalization. In that
event, the difference between what the decedent transferred
to HBC and what he received is $256 and the gifts will be
valued in the aggregate amount of $103,040. In passing, we
note respondent does not take the position that, for
purposes of valuing decedent's stock, we must take into
account the voting stock transferred to the corporation by
Ms. Baker.
Generally, the gift tax applies to a transfer of
property by way of gift. Secs. 25.2501-1(a)(1), 25.2511-
1(a), Gift Tax Regs. As mentioned above, the value of the
property at the date of the gift is considered the amount
of the gift. Sec. 2512(a). Thus, for purposes of
computing the gift tax, each separate gift must be valued
separately. Rushton v. Commissioner, 498 F.2d 88, 93
(5th Cir. 1974), affg. 60 T.C. 272 (1973); Calder v.
Commissioner, 85 T.C. 713, 720-721 (1985); Standish v.
Commissioner, 8 T.C. 1204, 1209 (1947); Clause v.
Commissioner, 5 T.C. 647, 649-650 (1945), affd. per curiam
154 F.2d 655 (3d Cir. 1946); Avery v. Commissioner, 3 T.C.
963, 970 (1944); Phipps v. Commissioner, 43 B.T.A. 1010
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