T.C. Memo. 1996-148
UNITED STATES TAX COURT
ESTATE OF FREDERICK CARL GLOECKNER,
DECEASED, JOSEPH A. SIMONE, AND
DOUGLAS DILLON, CO-EXECUTORS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8747-94. Filed March 25, 1996.
R determined a deficiency in Federal estate tax
liability. R contends that decedent’s executors
underreported the value of certain shares of stock in a
closely held corporation that D held on the date of his
death. Those shares were subject to a restrictive
agreement that obligated decedent’s executors to sell,
and the company to buy, a certain number of shares. R
contends that the value of D’s shares is $4,580,000.
The executors contend that the value of those shares is
$2,298,161.25, which is the amount received by the
estate pursuant to the restrictive agreement.
1. Held: The price term in the restrictive
agreement does not control the value of the stock for
Federal estate tax purposes.
2. Held, further, the value of the stock for
Federal estate tax purposes is $4,000,000.
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