T.C. Memo. 1996-49 UNITED STATES TAX COURT ESTATE OF JOSEPH R. CLOUTIER, JOSEPH A. CLOUTIER, FIDUCIARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8905-94. Filed February 13, 1996. C is a corporation whose stock is not listed on an exchange. D owned 100 percent of the stock when he died. D’s stock was valued at $12,582,000 on the estate’s Federal estate tax return. After R determined that the stock should have been valued at $15,440,000, the parties stipulated that the stock was worth $12,250,000, without regard to any marketability discount or control premium that would otherwise apply. The parties’ stipulation followed their receipt of appraisals of the stock’s value. R’s sole appraisal stated that the stock was worth $12,619,000. F’s three appraisals stated that the stock was worth $11,625,000, $11,652,555 and $11,850,000, respectively. In making these appraisals, none of the appraisers determined the stock’s value by reference to the price of comparable listed stock. Held: Because the stipulated value has not been shown to be representative of C’s “freely traded value”, no discount for marketability is allowable.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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