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(1941), affd. 127 F.2d 214 (10th Cir. 1942); Adair v.
Commissioner, T.C. Memo. 1987-494; Hipp v. Commissioner,
T.C. Memo. 1983-746; Whittemore v. Fitzpatrick, 127 F.
Supp. 710 (D. Conn. 1954). For example, we have rejected
attempts by taxpayers to aggregate separate gifts of stock
made on the same day in order to claim a blockage discount,
and we have held that each separate gift must be valued
separately. See, e.g., Rushton v. Commissioner, 60 T.C.
272 (1973); Phipps v. Commissioner, supra. Similarly, we
have rejected an attempt by the Commissioner to aggregate
separate gifts of stock made on the same day by a majority
stockholder to members of his family in order to value the
gifts as "control stock". See Estate of Heppenstall v.
Commissioner, a Memorandum Opinion of this Court dated
Jan. 31, 1949. We have applied the principle of valuing
separate gifts separately not only in the case of the gifts
made by a donor directly to several donees but also in the
case of gifts made indirectly through a trust. See, e.g.,
Calder v. Commissioner, supra at 720-721; Avery v.
Commissioner, supra; See generally Helvering v. Hutchings,
312 U.S. 393 (1941); Whittemore v. Fitzpatrick, supra.
As mentioned above, a transfer of property to a
corporation for less than adequate and full consideration
generally represents gifts by the donor to the individual
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