Harold J. Jungbluth, Special Administrator of the Estate of John Jungbluth v. United States

The sole question before us on this appeal is the correct value to be given to certain shares of stock, as of May 15, 1958, for federal gift tax purposes.

On that date, John W. Jungbluth (taxpayer) made a gift of 200 shares of common stock of the R T & E Corporation to his son, Harold, and a like gift of 200 shares to his daughter-in-law, Marion, wife of Harold.

Taxpayer assigned each share of such stock a value of $35, and paid a total federal gift tax of $45.

The Commissioner of Internal Revenue assigned a value of $190 per share to the 400 shares in issue and assessed a deficiency…