T.C. Memo. 1999-37
UNITED STATES TAX COURT
ESTATE OF DOROTHY B. FOOTE, DECEASED, JOHN BRUMDER AND
CAROL COLLINS, PERSONAL REPRESENTATIVES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 621-98. Filed February 5, 1999.
James William Callison and Jeanne M. Coleman, for
petitioner.
Frederick J. Lockhart, Jr. and John A. Weeda, for
respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $52,340.53 deficiency
in the Federal estate tax of the Estate of Dorothy B. Foote.
Following concessions, the sole issue for decision is the fair
market value (after application of the appropriate blockage
discount) of 280,507 shares of Applied Power, Inc. (Applied Power
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