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Docket No. 14997-94:
Type of Tax Period Date of Death Deficiency
Estate 1990 9/5/90 $204,900
Docket No. 15051-94:
Type of Tax Period Deficiency
Gift 1989 -- $46,517
Gift 1990 -- 782,159
By an amended answer filed in each of the above cases,
respondent asserts that the estate tax deficiency is
$2,157,593, rather than the above amount determined in the
notice of deficiency, and that the gift tax deficiency for
1990 is $1,581,641, rather than the above amount determined
in the notice of deficiency.
After concessions, the issue for decision in these
consolidated cases is the value of the gifts that the
decedent made to his two sons by means of a 1990
transaction in which he and his wife exchanged voting
common stock in his closely held corporation for nonvoting
common stock with the result that his sons ended up owning
all of the voting stock of the corporation.
FINDINGS OF FACT
Some of the facts have been stipulated by the parties
and are so found. The stipulation of facts filed by the
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