Legal Opinion
Ralph Penn v. Commissioner of Internal Revenue, Albert Penn v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 15, 1955No. 13689, 13702PublishedCited by 23 opinions
1Opinion of the Court
JAMES ALGER FEE, Circuit Judge.
These consolidated proceedings in volve deficiencies in gift taxes determined for 1946 against petitioner Albert Penn and for 1946 and 1947 against petitioner Ralph Penn. During these years, the taxpayers each made gifts of shares of Penn Electric Switch Company common stock and reported the values thereof per share on their respective gift tax returns for those years. The Commissioner determined that the fair market value of the above mentioned common stock was $20.00 per share on each of the respective dates of the gifts thereof, and issued notices of…
2Cited by23 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
- Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
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