Estate of Bonnie I. Barge, Deceased, C. Richard Barge, Executor - Page 1

                                 T.C. Memo. 1997-188                                  

                               UNITED STATES TAX COURT                                

                        ESTATE OF BONNIE I. BARGE, DECEASED,                          
                      C. RICHARD BARGE, EXECUTOR, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 230-92.               Filed April 23, 1997.                 

                    At issue is the valuation of a 25-percent                         
               undivided interest in timberland that was the subject                  
               of gifts made by donor.  R determined a deficiency in                  
               Federal gift tax based on her valuation of the                         
               interest.  Held:  Value of interest determined by                      
               discounting partition award to present value.                          

               Harris H. Barnes III and John V. Eskrigge, for petitioner.             
               Robert W. West, for respondent.                                        

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