-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 Next
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