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During the years in issue, petitioner Robert W. Fritz was
the proprietor of Fritz Tree Service, a tree trimming business in
Washington, Pennsylvania. Mr. Fritz reported his income and
deductions from this business on a Schedule C (Profit or (Loss)
From Business or Profession), which he attached to petitioners'
Federal income tax returns. Fritz Tree Service operated on the
cash method of accounting.2
La-Z-Boy Stock
Selma M. Fritz, the mother of petitioner Robert W. Fritz,
died on January 15, 1981. Mr. Fritz was the executor of his
mother's estate, and he filed a Petition for Probate and Grant of
Letters with the Register of Wills in Washington County,
Pennsylvania. On January 20, 1981, Selma Fritz' will was
admitted to probate, and Letters Testamentary were granted to Mr.
Fritz.
At the time of her death, Selma Fritz owned 17,148 shares of
La-Z-Boy Chair Co. (La-Z-Boy) stock. These shares were included
in Selma Fritz' gross estate as reported on Form 706 (United
States Estate Tax Return) and were valued at $10.125 per share,
their fair market value on the date of Selma Fritz' death. On
July 22, 1982, the IRS issued an Estate Tax Closing Letter in
2The record contains no other evidence regarding the nature
of Mr. Fritz' business. The parties did not offer a stipulation
of facts, and Mr. Fritz did not testify at trial.
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