Groff v. Smith

Finding of Facts

PIINCKS, District Judge.

A. All the facts of this case are stated in an extensive stipulation which may be deemed a part hereof. I think, however, the following resume will suffice for an understanding of the rulings which I shall presently indicate:

B. 1. The plaintiff on November 11, 1936, gave 14,000 shares of Electrolux Corporation to his wife, and paid a gift tax thereon based on a valuation of $23,375 per share, which was the average mean selling price on the Montreal Exchange for November 10 and November 12 (November 11 being a holiday). Thereafter the plaintiff duly…