- 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