Estate of Frederick Carl Gloeckner, Deceased, Joseph A. Simone, and Douglas Dillon, Co-Executors - Page 11

                                       - 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

Last modified: May 25, 2011