-13-
G. Petitioner's Gifts of Crossroads' Stock
On December 31, 1991, petitioner owned 9,600 of the 10,000
shares of common stock of Crossroads and all of the 750,000
shares of preferred stock of Crossroads. The remaining 400
shares of the common stock were owned equally by Paula Dockery,
Mavis Dockery, Carl Dockery, and Michele Jones. On January 1,
1992, and January 1, 1993, petitioner gave the following number
of shares of Crossroads' stock to his children:
Donee Date of gift Common shares
Carl Dockery 1/1/92 448
Michele Jones 1/1/92 445
Carl Dockery 1/1/93 637
Michele Jones 1/1/93 637
These shares represented a minority interest in Crossroads.
H. Gift Tax Returns and Notice of Deficiency
Based on a June 22, 1992, appraisal by KPMG Peat Marwick,
petitioner reported on his 1992 and 1993 gift tax returns that
the fair market value of Crossroads' stock was $303 per share on
January 1, 1992, and January 1, 1993. Petitioner paid gift tax
of $16,749 for 1993.
Respondent determined that the fair market value of
Crossroads' common stock was $704 per share on January 1, 1992,
and $1,010 per share on January 1, 1993.
II. OPINION
The sole issue for decision is the fair market value of
Crossroads' stock that petitioner gave to his children on January
1, 1992, and January 1, 1993.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011