-2-
1. Whether the fair market value in 1992 of Crossroads
Insurance, Inc.'s stock that petitioner gave to his children was
$628,619 ($704 per share), as respondent contends; zero, as
petitioner contends; or some other amount. We hold that it was
$303 per share.
2. Whether the fair market value in 1993 of Crossroads
Insurance, Inc.'s stock that petitioner gave to his children was
$1,286,961 ($1,010 per share), as respondent contends; $274,101
($215 per share), as petitioner contends; or some other amount.
We hold that it was $303 per share.
Unless otherwise specified, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
I. FINDINGS OF FACT
A. Petitioner
Petitioner is Charles Dockery. Petitioner's mailing address
was Lakeland, Florida, when he filed the petition.
Paula Dockery is petitioner's wife. Mavis Dockery is
petitioner's former wife. Carl Dockery is petitioner's son.
Michele Jones (formerly Michele Renwald) is petitioner's
daughter.
B. Crossroads Insurance, Inc.
Petitioner incorporated Crossroads Insurance, Inc.
(Crossroads), under the Companies Law of the Cayman Islands on
June 27, 1978. Petitioner has been the majority shareholder and
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