- 44 - $15,105.74 per share for gift tax purposes. The original Buy-Sell Agreement was entered into in May 1975 and set the price for CamVic stock at $11,333.30 per share. Neither petitioners nor their expert gave any explanation for the approximately $4,000 (or greater than 25 percent) decline in the value of CamVic stock between 1974 and 1975. Moreover, following our review of the record, we have also been unable to find any reason--outside of estate tax planning--to justify such a decline in value. We conclude that petitioners have not met their burden of proving that the price per share set forth in the Buy-Sell Agreement or the Revised Agreement reflected adequate and full consideration for decedent's interest in CamVic stock.33 Estate of Gloeckner v. Commissioner, T.C. Memo. 1996-148; Estate of Lauder v. Commissioner, T.C. Memo. 1992-736. Thus, we hold that the fixed price of $11,333.30 price per share set forth in both agreements is not binding for estate tax purposes. As a result of our decision, further proceedings will be necessary to determine the actual fair market value of CamVic stock at the time of decedent's death on September 10, 1990. Appropriate orders will be issued. 33Even petitioners' expert determined that the value of CamVic's stock exceeded $11,333.30 per share as of April 1981.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44
Last modified: May 25, 2011