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Bosca because, in this case, there is no difference between the
valuation of petitioner’s gifts to his sons depending on whether
the gifts are valued on an aggregate basis or separately. The
value of 50 percent of the gifted property, or $378,532 (50
percent of $757,064), less a 15-percent discount is the same as
two 25-percent undivided interests in the leased land, $378,532,
less a 15-percent discount.
In valuing the gifts in Estate of Bosca, it was necessary
for the Court to decide whether the gifts should be valued on an
aggregate basis; i.e., as part of a 50-percent block of stock, or
whether they should be valued separately; i.e., as two 25-percent
blocks of stock. In deciding to take the latter approach, we
followed the long-standing position of this Court that separate
gifts must be valued separately. See, e.g., Calder v.
Commissioner, 85 T.C. 713 (1985); Rushton v. Commissioner, 60
T.C. 272, 278 (1973), affd. 498 F.2d 88 (5th Cir. 1974); Standish
v. Commissioner, 8 T.C. 1204 (1947); Phipps v. Commissioner, 43
B.T.A. 1010-1022 (1941), affd. 127 F.2d 214 (10th Cir. 1942);
Hipp v. Commissioner, T.C. Memo. 1983-746.
As I understand their position, Judges Ruwe and Beghe agree
that, under the facts of this case, petitioner made a gift to
each of his two sons, but they do not agree with the approach
used by the majority in valuing the gifts. They appear to take
the position that in computing the difference between the value
of the property transferred by the donor and the value of the
consideration received by the donor, as required by section
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