Maude G. Furman, Donor, Deceased, and Estate of Maude G. Furman, Deceased, Robert G. Furman, Executor - Page 2

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                              Estate of Maude G. Furman                               
                                             Additions to Tax                         
                             Deficiency     Sec. 6651(a)   Sec. 6653(a)              
               Gift tax--     $75,460        $18,865        $3,773                    
          1981                                                                        
               Estate Tax     115,649             --             --                   
                              Estate of Royal G. Furman                               
                                             Additions to Tax                         
                             Deficiency     Sec. 6651(a)   Sec. 6653(a)              
               Gift tax--     $75,460        $18,865        $3,773                    
          1981                                                                        
               After concessions regarding the estate tax deficiency, the             
          issues for decision are:                                                    
               1.   Whether for purposes of computing the taxable gifts of            
          Royal G. Furman (Royal) and the taxable gifts and taxable estate            
          of Maude G. Furman (Maude), the fair market value of 24 shares of           
          Furman's, Inc. (FIC) common stock exchanged by each of Royal and            
          Maude in 1981 for preferred stock of FIC was $300,000 ($12,500              
          per share) as petitioners contend, $540,540 ($22,522 per share)             
          as respondent contends, or some other amount.  We hold that the             
          fair market value was $424,552 ($17,690 per share).                         
               2.   Whether for purposes of computing Maude's taxable                 
          estate, the fair market value of six shares of FIC common stock             
          that she transferred to Robert G. Furman (Robert) in 1980 was               
          $62,016 ($10,336 per share), as petitioners contend, $147,600               
          ($24,600 per share), as respondent contends, or some other                  
          amount.  We hold that the fair market value was $82,859 ($13,810            
          per share).                                                                 



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