Estate of Arthur G. Scanlan, Deceased, Ruth B. Scanlan, Administratrix - Page 2

                                           - 2 -                                             
                         MEMORANDUM FINDINGS OF FACT AND OPINION                             

                LARO, Judge:  The Estate of Arthur G. Scanlan, Deceased,                     
          Ruth B. Scanlan, Administratrix, petitioned the Court to                           
          redetermine respondent’s determination of a deficiency in                          
          Decedent’s Federal estate tax.  Respondent determined a $426,111                   
          deficiency.                                                                        
                The parties dispute the value1 of Decedent’s stock in                        
          Eatelcorp, Inc. (Eatel), on:  (1) The date of his death and                        
          (2) the date of a gift that was made approximately 3 months                        
          beforehand (these two dates are collectively referred to as the                    
          Valuation Dates).  Ruth B. Scanlan, Administratrix                                 
          (Administratix), argues that the per-share values were $35.20 at                   
          Decedent's death and $34.84 on the date of the gift.  Respondent                   
          determined that the per-share value was $72.15 on both dates.                      
                We hold that the per-share value was $50.50885 on both                       
          dates.  Unless otherwise stated, section references are to the                     
          Internal Revenue Code in effect for the Valuation Dates.                           
          Rule references are to the Tax Court Rules of Practice and                         
          Procedure.  Dollars, unless otherwise noted, are rounded to the                    
          nearest dollar.                                                                    
                                     FINDINGS OF FACT                                        



                1 Throughout this Memorandum Opinion, we sometimes use the                   
          shorthand “value” to refer to fair market value.                                   




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