- 2 - contends; or some other amount. We hold that decedent owned 81,641 shares at the time of her death. 2. Whether, for purposes of computing the taxable estate of decedent, the fair market value of the shares of Johnco common stock included in decedent's gross estate was $4,100,000 ($50.94 per share) as petitioner contends, at least $6,278,899 ($77 per share) as respondent contends, or some other amount. We hold that the fair market value was $5,784,477 ($71 per share). 3. Whether the method prescribed for the computation of the Federal estate tax transforms any part of such tax into a direct tax which has not been apportioned in accordance with the Constitution. We hold that it does not. Unless otherwise noted, all section references are to the Internal Revenue Code in effect on the date of decedent’s death, and all Rule references are to the Tax Court Rules of Practice and Procedure. All amounts have been rounded to the nearest whole dollar. Some of the facts have been stipulated and are incorporated herein by this reference. FINDINGS OF FACT I. Decedent Petitioner is the Estate of Helen Bolton Jameson, deceased (the Estate), who died testate on September 22, 1991. Northern Trust Bank of Texas (Northern Trust) is the independent executor of the Estate. Decedent was a resident of Texas at the time of her death. Decedent was predeceased by her husband, John B.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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