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the Estate. We refer to the Estate’s fiduciary (Joseph A.
Cloutier) as the Fiduciary.
Background
The stipulations and attached exhibits are incorporated
herein by this reference. The Decedent died on December 11,
1989, while a resident of Indiana. The Fiduciary, a resident of
Indiana when he petitioned the Court, filed a Form 706, United
States Estate (and Generation-Skipping Transfer) Tax Return, on
behalf of the Decedent's estate. Form 706 reflects the
Fiduciary’s election of an alternate valuation date under section
2032. The alternate valuation date is June 11, 1990.
Corporation for General Trade (CGT) is a corporation whose
stock is not listed on an exchange. CGT’s stock was entirely
owned by the Decedent when he died. CGT’s principal asset at the
time of the Decedent’s death was 100 percent of the stock of
Thirty-Three, Inc. (Thirty-Three). Thirty-Three owned and
operated the NBC television affiliate in Fort Wayne, Indiana.2
Other assets of CGT at the time of the Decedent’s death included
rental real estate and a motor home.
On the Form 706, the Decedent’s CGT stock was valued at
$13,969,000 on the date of his death, and $12,582,000 on the
alternate valuation date. These values were based on two
2 After the Decedent died, but before the alternate
valuation date, Thirty-Three was merged into CGT, so that only
CGT existed on the alternate valuation date.
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