- 2 - section references are to the Internal Revenue Code in effect as of the date of the decedent's death. Rule references are to the Tax Court Rules of Practice and Procedure. The term "coexecutors" refers to the estate's coexecutors, Newton G. Welch, Jr. (Newton) and Lois Welch McGowan. Background This case was submitted fully stipulated under Rule 122. The stipulation of facts and the exhibits submitted therewith are incorporated herein by this reference. When the petition was filed, the coexecutors resided in Nashville, Tennessee. Pauline Welch (decedent) died on March 18, 1993. At the time of her death, decedent was a minority shareholder in two closely held corporations, Electric Services, Inc. (ESI) and Industrial Sales Co., Inc. (ISC). On the date of decedent's death, ESI had 570 shares issued and outstanding (110 voting common shares/460 nonvoting common shares) of which decedent owned 259 nonvoting common shares; ISC had 836 shares issued and outstanding (150 voting common shares/686 nonvoting common shares) of which decedent owned 259 nonvoting common shares. The coexecutors, decedent's son and daughter, equally inherited decedent's property, including the common nonvoting shares of ESI and ISC. The remaining shares of both corporations, voting and nonvoting common, were held in a trust established under the willPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011