Robert W. and Jennifer J. Fritz - Page 3

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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.           
               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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