Cameron W. Bommer Revocable Trust, Ronald Bommer, Trustee - Page 2

                                        - 2 -                                         

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               RUWE, Judge:  In docket No. 15484-94, respondent determined            
          a deficiency in petitioner Cameron W. Bommer Revocable Trust's              
          generation-skipping transfer tax in the amount of $1,117,233.  In           
          docket No. 15485-94, respondent determined a deficiency in                  
          petitioner Estate of Cameron W. Bommer's Federal estate tax in              
          the amount of $4,393,397 and generation-skipping transfer tax in            
          the amount of $1,117,233.                                                   
               The issue before us is the effect, if any, of a restrictive            
          stock agreement on the value of certain stock in CamVic Corp.               
          that is includable in the Estate of Cameron W. Bommer (decedent).           
          We severed this issue for trial and opinion.  The remaining                 
          issues, if not settled, will be decided in subsequent                       
          proceedings.                                                                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as in effect for the date of decedent's           
          death, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts is incorporated herein by this                     
          reference.                                                                  






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