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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.
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Last modified: May 25, 2011