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Background
On June 8, 1972, John P. Hahn, petitioner's husband, signed
a subscription agreement to purchase shares in Fifty CPW Tenants
Corporation (CPW) for a purchase price of $44,000. On
February 15, 1973, 440 shares of CPW were issued to petitioner
and her husband as joint tenants with right of survivorship.
These shares were allocated to apartment 10C, located at 50
Central Park West, New York, New York.
On August 19, 1991, Mr. Hahn died, and petitioner became the
sole owner of the CPW shares. On July 8, 1993, the estate of
John P. Hahn filed a Federal Estate Tax Return reporting 100
percent of the value of the CPW shares on the date of Mr. Hahn's
death as the value of his interest in the shares. The value of
the shares on the date of Mr. Hahn's death was reported at
$700,000.
Petitioner sold the CPW shares on September 28, 1993. On a
Form 2119 (Sale of Your Home) attached to her 1993 Federal income
tax return, petitioner reported a selling price for the CPW
shares of $720,000 and a basis of $758,412.2 Accordingly,
petitioner reported no gain on the sale.
In a notice of deficiency issued June 17, 1996, respondent
determined, inter alia, that, pursuant to section 2040(b)(1),
2On a statement attached to her return, petitioner
calculated her basis as follows: $700,000 date of death value,
$572 of transfer fees, $43,200 of commissions, $13,140 of
transfer taxes, and $1,500 for asbestos removal.
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Last modified: May 25, 2011