Estate of Mario E. Bosca, Deceased, Marie A. Baker Formerly Marie A. Bosca, Executor - Page 31

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             shareholders of the corporation to the extent of their                   
             proportionate interests in the corporation.  Kincaid v.                  
             United States, supra at 1224, 1226; Heringer v.                          
             Commissioner, 235 F.2d 149 (9th Cir. 1956); CTUW Georgia                 
             Ketteman Hollingsworth v. Commissioner, 86 T.C. at 96-97.                
             Sec. 25.2511-1(h)(1), Gift Tax Regs.  Applying the                       
             principle that separate gifts must be valued separately, it              
             follows that each such gift to a stockholder of a                        
             corporation must be valued separately.  Cf. Estate of                    
             Hitchon v. Commissioner, 45 T.C. 96 (1965).                              
                  In these cases, the decedent through his participation              
             in the recapitalization indirectly made gifts to his two                 
             sons.  In valuing the gifts, respondent takes the position               
             that the stock transferred by the decedent to the                        
             corporation should be treated as a single block of stock                 
             and should be valued accordingly.  Thus, respondent has                  
             aggregated the decedent's stock for purposes of valuing the              
             gifts he made to his sons.  In our view, this approach                   
             violates the principle that separate gifts should be valued              
             separately.  We agree that the decedent surrendered stock                
             in the recapitalization that represented 50 percent of the               
             voting stock of the corporation.  However, the decedent did              
             not convey 50 percent of the voting stock of the                         
             corporation to either of the donees or to both of them                   





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