- 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 NashvillePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011