T.C. Memo. 1999-119 UNITED STATES TAX COURT ESTATE OF ALICE FRIEDLANDER KAUFMAN, DECEASED, JAMES J. MORRISSEY, ALAN S. BERCUTT AND DIANE FANTL, CO-EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17050-97. Filed April 6, 1999. S is a family-owned corporation, and D's estate (E) includes 46,020 shares of S's class A stock. E's shares represent 19.86 percent of S's total outstanding shares and is the largest block of S stock owned by one person. E reported on its Federal estate tax return that the fair market value of these shares was $29.77 each on the applicable valuation date. E primarily based its value on two sales of S stock that took place approximately 2 months after the valuation date; two members of D's extended family sold their interests in S (4.67 and 3.25 percent, respectively) to a third member without investigating the reasonableness of the sale price and without negotiation. R determined that the fair market value of E's stock was $70.79 per share. Held: The fair market value of E's stock on the applicable valuation date was $56.50 per share. The sales upon which E relies are not indicative of the value of E's stock; among other things, the sellers were not knowledgeable of the value of their stock, andPage: 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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