- 11 - $2,298,161.25. That was the amount paid for the shares under the 1987 redemption agreement. The executors elected alternate valuation, as provided for in section 2032. Value of Decedent’s Shares The value of decedent’s shares on the alternate valuation date was $4,000,000. OPINION I. Introduction A. Questions Presented This case concerns the value for Federal estate tax purposes of certain shares of stock in Fred C. Gloeckner & Co. (the company) owned by decedent at the time of his death. The executors of decedent’s estate valued those shares at $2,298,261.25 on the estate tax return they filed. In the statutory notice of deficiency, respondent determined that the value of the shares (decedent’s shares) was $6,000,000. At trial, however, respondent conceded that the value of decedent’s shares was, at most, $4,580,000. B. Arguments of the Parties The executors claim that the value of decedent’s shares is the value stated in the estate tax return because that is the amount paid by the company pursuant to the 1987 redemption agreement. They argue that the 1987 redemption agreement established the fair market value of those shares because it was a binding agreement entered into for a valid business purpose.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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