- 30 - (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 individualPage: 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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