Estate of Mario E. Bosca, Deceased, Marie A. Baker Formerly Marie A. Bosca, Executor - Page 30

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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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