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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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