T.C. Memo. 1996-372
UNITED STATES TAX COURT
ESTATE OF ROSS H. FREEMAN, DECEASED,
DENNIS HERSEY, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22427-93. Filed August 13, 1996.
R determined a deficiency in estate tax. The sole
issue for decision is the fair market value on the date
of decedent's death of certain shares of common stock
and an option to acquire additional shares of common
stock that were properly includable in decedent's gross
estate.
Held: R's valuation of such shares and the option
is sustained, except that allowance will be made for
the exercise price of the option shares.
Leroy J. Neider, for petitioner.
Kimberley J. Peterson, for respondent.
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