disallowed, of The court "Prom parties the and said: facts other disclosed evidence, by it the stipulation appears that the amount paic by the transferee was so trivial as compared with the value of the stock transferred as to require the conelusion that the transaction not in reality a sele, but operate was &8 & that purvorted mere gnam, gift; * * * transaction in the was Circumstances question, intended sale attending notably the it, kept that from heving the semblance valuable consideration." the gum of ea real NO Ehrhart case paid to, review that is an authority in the case, our conference at Washington, not loss occurring Tre judgement same stock Was asked to discuss instant the Sshoenberg 77? Fed, v. Commissioner, 2d 446, proceeding was on sun Claimed number of owned more refused to allow the dedue~ petitioner the enc of the directed shares on the New York Stock time vlaced an order to shares for a corporation seventy per cent through defendant, towards same than the etocks, game the of corporate certain the taxes income of the at taxpayer sale for and the «4 went sell by represent year to of to thet taxpeyer, hereinbefore case ea petition the by in fhe the (CCA B), of Commissioner a large nechange, the were The of broker a demonstrate tion his for to redetermination petitioner. sale recuired we a transaction ia The to of and the stock comment During referred for a the relation father and son between the parties to it eross Cisparity between the valueof the ang to was he (70%) year, by purchase whose him and