- 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1, 1989, the corporation's S election was revoked.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
Last modified: May 25, 2011