- 6 - For at least each of the 10 years prior to decedent’s death, Brookshire paid cash dividends to its shareholders. On November 20, 1993, the date of decedent’s death -- based on an approximate total book value for Brookshire of $164,764,000 -- the per-share formula price under the buy-sell and stock- purchase agreements for the shares of Brookshire common stock owned by decedent’s estate was $73.43 per share. Prior to decedent's death, no blocks of Brookshire common stock anywhere near as large as decedent's block of 219,710 shares had been sold. In fact, in the 3 years prior to decedent’s death, the largest block of Brookshire common stock that had been sold consisted of 6,111 shares. Prior to decedent’s date of death, it appears that each sale of Brookshire stock constituted a non-arm’s-length sale. On August 22, 1994, decedent’s estate sold 29,410 shares of Brookshire common stock back to Brookshire for $79.50 per share in order to provide cash to the estate for payment of decedent’s reported estate tax liability. On August 23, 1994, petitioner timely filed decedent's Federal estate tax return. Based on an appraisal, the total value of the 219,710 shares of Brookshire common stock owned directly and indirectly by decedent’s estate was reported on the estate tax return at $12,907,962 or $58.75 per share.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011