Estate of Alice Friedlander Kaufman - Page 10




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               As of the beginning of the second quarter of 1994, the U.S.            
          economy had a largely positive outlook.  It had enjoyed 12                  
          straight quarters of economic growth and was experiencing some of           
          the lowest interest and inflation rates in more than two decades.           
          As of the alternate valuation date, market growth for the uniform           
          industry was anticipated; the career apparel sector of the                  
          uniform industry was growing rapidly, as companies learned the              
          benefits of easily identifiable employees and advertising created           
          by the professional image.                                                  
               Seminole budgeted approximately $1.5 million to be spent in            
          its 1994 fiscal year on expansion and a new computer system.                
                                       OPINION                                        
               We must determine the fair market value of the estate's                
          Seminole stock on the applicable valuation date.  Fair market               
          value is a factual determination, and the trier of fact must                
          weigh all relevant evidence of value and draw appropriate                   
          inferences.  See Commissioner v. Scottish Am. Inv. Co., 323 U.S.            
          119, 123-125 (1944); Helvering v. National Grocery Co., 304 U.S.            
          282, 294 (1938); Symington v. Commissioner, 87 T.C. 892, 896                
          (1986); Zmuda v. Commissioner, 79 T.C. 714, 726 (1982), affd.               
          731 F.2d 1417 (9th Cir. 1984).  Fair market value is measured on            
          the applicable valuation date, which, in this case, is 6 months             
          after the day decedent died.  See sec. 2032(a); Estate of Proios            
          v. Commissioner, T.C. Memo. 1994-442; see also Pabst Brewing Co.            
          v. Commissioner, T.C. Memo. 1996-506.  When the Commissioner                
          determines fair market value, as is the case at hand, taxpayers             


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