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MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners' gift tax for 1992 as follows:
Taxpayer Docket number Deficiency
Louise Barnes 13850-96 $169,039
John M. Barnes 13851-96 169,143
Edwin L. Barnes 13852-96 169,039
Frank S. Barnes, Jr. 13856-96 196,226
Mary Anne G. Barnes 13857-96 196,226
Jean D. Barnes 13896-96 169,143
Vera W. Helmly 14049-96 133,350
Robert L. Helmly 14050-96 133,350
The issues for decision are:
1. Whether the fair market value of Home Telephone Co.
voting common stock in January and December 1992 was $389 per
share, as respondent contends; $216.56 per share, as petitioners
contend; or some other amount. We hold that it was $227.41 per
share.
2. Whether the fair market value of Rock Hill Telephone
Co. nonvoting common stock in December 1992 was $410 per share,
as respondent contends; $186.55 per share on December 22, 23, and
26, 1992, and $179.03 per share on December 30, 1992, as
petitioners contend; or some other amount. We hold that it was
$201.12 per share on December 22, 23, and 26, 1992, and $193.34
per share on December 30, 1992.
Section references are to the Internal Revenue Code in
effect for the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
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