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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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