- 3 - Deft is an S corporation that manufactures and sells industrial coatings for military and commercial aircraft, heavy duty trucks, and construction equipment. Deft also manufactures and sells finishes and wood stains. Deft, like other paint companies, is a hazardous waste producer. From 1974 until 1991, Deft disposed of its hazardous waste at three disposal sites. As a result of its waste disposal, Deft faced large potential environmental liabilities. On decedent's estate tax return, petitioner reported that the fair market value of decedent's interest in Deft was $6,160,576. This included a $2,306,250 reduction for Deft's potential environmental liabilities. KPMG Peat Marwick (KPMG) computed this figure for purposes of preparing the estate tax return. In addition to owning Deft stock, decedent also owned two pieces of real property at his death. On the estate tax return, petitioner reported that on the alternate valuation date the fair market value of the Newport property was $800,000. On or about May 6, 1994, the Newport property was sold for a net sales price of $699,933. On the estate tax return, petitioner reported that on the alternate valuation date the fair market value of the Indian Wells property was $280,000. On or about July 29, 1994, the Indian Wells property was sold for a net sales price of $267,782.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011