April Mr. M. Dear A. Browning, Ogden, Utah. Mr. 27, 1939 Browning: Mr. Steckel discussed with us the question of a transfer of stock from Mrs. Monide B. Cwnsings to her husband, the question being raised in a recent letter received from Mrs. Cummings. We II (8) reads find that Gift Tax Regulation 79, Article as follows: "If A with his own funds purchases property and has the title thereto conveyed to himself and 5 as joint tenants, with rights of survivorship, but which rights may be defeated and either party severing his interest, there is a gift to B in the amount of one-half the value of such property." it is our opinion that this section of the regulations applies to the preposed transfer. Mrs. Gummings would transfer stock in the J. M. & M@. &. Browning Company with a value of $80,000.00 to herself and husband as joint tenants and inasmuch as one-half, or $40,000.00, is covered by the specific exemption allowed under the law, there would be no gift tax involved. $80,000.00, however, emption also and In the letter from Mrs. Cummings she mentioned inasmuch as thers is a $40,000.00 specific ex- a $4,000.00 exclusion, we suggest that the figure be used, if the transfer is made. We also suggest value placed upon the stock of the J. M. & M. &. Browning should be estimated, taking into consideration the values gifts made of this stock by yourself Undoubtedly before this transfer they will request an Me. &@M. &. Browning Company at the desire to have this appraisal made glad to do the basis this for upon gifts receipt Mr. Val the government 113 31, "If the property was the basis shall of the donor or the be in the hands by whom was not acquired Browning. by from A of 1920 1920, 31, that the Company used in passes upon appraisal of the assets of the date of gift. If it is your for Mrs. Cummings, we will be instructions Under Section after December December it of and $88,000.00 gift, you. the Revenut Act is as follows: acquired be the last by gift same as preceding except J. that of 1938 after it would owner for the