- 5 -
by decedent x 259 x 259
Value of decedent's
shares per estate tax
return (Form 706) 264,398 330,491
On December 22, 1993, the coexecutors filed a Form 706, United
States Estate (and Generation-Skipping Transfer) Tax Return,
electing the date of death as the valuation date. The reported
value of the ESI and ISC stock is $264,398 and $330,491,
respectively, for a per share value of $1,020.84 and $1,276.03,
respectively.
On March 4, 1994, Newton acquired all of the voting and
nonvoting shares of both ESI and ISC which he did not already own
from Lanny B. McGowan, his brother-in-law, and Lois Welch McGowan
(collectively the McGowans) for $2,100,000. At the time of the
transaction, Newton and the McGowans each owned 50 percent of
ESI's and ISC's voting and nonvoting shares. The purchase price
for the nonvoting shares of ESI and ISC was $1,021 and $1,276 per
share, respectively, the approximate per share value identified
on the estate's tax return. The remainder of the purchase price
was allocated equally between ESI's and ISC's voting stock.
Newton, as the buyer in the stock purchase agreement, covenanted
that ESI and ISC would purchase real property to relocate the
businesses of ESI and ISC once possession of their respective
properties was lost to the Metropolitan Government of Nashville
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Last modified: May 25, 2011