Estate of Mario E. Bosca, Deceased, Marie A. Baker Formerly Marie A. Bosca, Executor - Page 29

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             in the aggregate amount of $970,830.  On the other hand, if              
             the stock is valued as two 25-percent blocks, then the                   
             parties have stipulated that each share of stock was worth               
             $9,671 immediately before the recapitalization.  In that                 
             event, the difference between what the decedent transferred              
             to HBC and what he received is $256 and the gifts will be                
             valued in the aggregate amount of $103,040.  In passing, we              
             note respondent does not take the position that, for                     
             purposes of valuing decedent's stock, we must take into                  
             account the voting stock transferred to the corporation by               
             Ms. Baker.                                                               
                  Generally, the gift tax applies to a transfer of                    
             property by way of gift.  Secs. 25.2501-1(a)(1), 25.2511-                
             1(a), Gift Tax Regs.  As mentioned above, the value of the               
             property at the date of the gift is considered the amount                
             of the gift.  Sec. 2512(a).  Thus, for purposes of                       
             computing the gift tax, each separate gift must be valued                
             separately.  Rushton v. Commissioner, 498 F.2d 88, 93                    
             (5th Cir. 1974), affg. 60 T.C. 272 (1973); Calder v.                     
             Commissioner, 85 T.C. 713, 720-721 (1985); Standish v.                   
             Commissioner, 8 T.C. 1204, 1209 (1947); Clause v.                        
             Commissioner, 5 T.C. 647, 649-650 (1945), affd. per curiam               
             154 F.2d 655 (3d Cir. 1946); Avery v. Commissioner, 3 T.C.               
             963, 970 (1944); Phipps v. Commissioner, 43 B.T.A. 1010                  





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