- 3 - treated as a subchapter S corporation. Subsequently, on January 1, 1989, the corporation's S election was revoked. During the years at issue, the corporation was a subchapter C corporation for Federal tax purposes. The principal asset of the corporation, other than cash, was a building in Brooklyn, New York (the property), which was leased to third parties. The corporation received income from the rents generated from the lease appurtenant to the property during the years at issue. Prior to and during the years at issue, the corporation's only income was from the active trade or business of renting the property. On December 23, 1991, the first transfer date, petitioner made gifts of 668 shares of stock in the corporation as follows: (1) 334 shares to her son, Joseph Eisenberg; (2) 167 shares to her granddaughter, Joanne B. Bayer; and (3) 167 shares to her grandson, David Blum. Subsequently, on September 30, 1992, the second transfer date, and on February 23, 1993, the third transfer date, petitioner gave as gifts 275 shares and 57 shares of stock in the corporation, respectively, to her son Joseph Eisenberg. The fair market value of the stock, after a 25-percent minority discount, was $517.20 per share on the first transfer date, $356.71 per share on the second transfer date, and $341.77 per share on the third transfer date.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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