John E. Wall - Page 1
















                                 T.C. Memo. 2001-75                                   


                               UNITED STATES TAX COURT                                


                             JOHN E. WALL, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                             JOANNE WALL, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 1590-98, 1850-98.          Filed March 27, 2001.           


                    These are gift tax valuation cases in which the                   
               transferred property is nonvoting common stock of a                    
               family corporation given by petitioners to 20 trusts                   
               for their 10 children.  The value per share determined                 
               by the statutory notices exceeded the value claimed in                 
               the gift tax returns by only 17 percent.  The reports                  
               prepared by the experts for trial came up with values                  
               that widened the gap between the parties’ initial                      
               positions.  In Buffalo Tool & Die Manufacturing Co. v.                 
               Commissioner, 74 T.C. 441, 451-452 (1980), the Court                   
               suggested that valuation cases should be settled, and                  
               warned the parties that in some cases the Court might                  
               be persuaded to adopt the position of one party, rather                
               than to split the difference between their positions;                  
               these are such cases.  Held:  the determination of                     
               value in the statutory notices is sustained.                           






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