- 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. 1010Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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