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Gregory V. Nelson, John W. Porter, and Richard A. Husseini,
for petitioner.
Victoria J. Sherlock, Norman N. Pickett, and Harve M.
Lewis, for respondent.
CHIECHI, Judge: Respondent determined a deficiency of
$5,283,894 in the Federal gift tax of Artemus D. Davis (decedent)
who died on June 11, 1995, after he made the two gifts to which
that deficiency pertains. The sole issue for decision is the
fair market value on November 2, 1992, of each of two blocks of
25 shares of common stock of A.D.D. Investment and Cattle Company
(ADDI&C), one of which decedent gave to his son Robert D. Davis
(Robert Davis) and the other of which decedent gave to his son
Lee W. Davis (Lee Davis).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Decedent, who was one of the founders of Winn-Dixie Stores,
Inc. (Winn-Dixie), died testate on June 11, 1995, while he was a
legal resident of Florida. Robert Davis, the personal
representative of decedent's estate, resided in Jacksonville,
Florida, at the time the petition was filed.
On or about November 2, 1992 (the valuation date), ADDI&C, a
closely held Florida corporation that was incorporated on
December 22, 1947, had a total of 97 shares of common stock
issued and outstanding, all of which were owned by a trust (Davis
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