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Deloitte & Touche also appraised the assets included in
Mrs. DiSanto's estate. Deloitte & Touche concluded that, as a
result of the disclaimer, Mrs. DiSanto’s estate was entitled to
receive 121,823 shares of MD&F stock from her husband with a fair
market value of $1,891,911 ($15.53 per share) as of June 4,
1993.3
Petitioners timely filed estate tax returns for the estates
of Mr. and Mrs. DiSanto and amended returns dated June 23, 1995.
Mr. DiSanto's estate reported that his 186,177 shares of MD&F
stock were worth $4,804,000 ($25.80 per share).
Mr. DiSanto's estate reported on Item 25, Schedule M
(Bequests, etc., to Surviving Spouse) of the estate tax return
that 121,823 shares of MD&F stock passed to Mrs. DiSanto. Mr.
DiSanto’s estate claimed a marital deduction of $3,143,055
(121,823 shares of MD&F worth $25.80 per share). Mrs. DiSanto's
estate reported on Item 20 of Schedule B (Stocks and Bonds) of
the estate tax return that her estate had 121,823 shares of MD&F
stock.
G. MD&F’s Redemption of Mr. DiSanto’s Stock in 1995 and
Bankruptcy in 1997
The DiSanto children considered selling Mr. DiSanto’s MD&F
stock to outsiders after their parents died. In August 1994,
Graham Reginald Pope (Pope), a certified public accountant,
3 The record does not indicate how Deloitte & Touche
calculated that number of shares.
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