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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.
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