Estate of Sam Homer Marmaduke - Page 2




                                        - 2 -                                         

          date of decedent's death or the valuation date), and all Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
               After settlement of some issues, the sole remaining issue              
          for decision is the fair market value, as of the date of                    
          decedent's death, of 366,385 shares of common stock of a closely            
          held corporation.                                                           

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time of decedent's death, decedent resided in                   
          Amarillo, Texas.  At the time the petition was filed, John H.               
          Marmaduke, the executor of decedent's estate, resided in                    
          Amarillo, Texas.                                                            
               Upon his death in 1993, decedent owned 366,385 shares or               
          approximately 22 percent of the total outstanding common stock in           
          Hastings Books, Music & Video, Inc. (Hastings).  Other members of           
          the Marmaduke family owned another 957,685 shares or 57 percent             
          of the total outstanding common stock in Hastings.  Together, the           
          Marmaduke family (including decedent's wife, children, and                  
          grandchildren) owned 79 percent of the total common stock in                
          Hastings.                                                                   
               Shareholders unrelated to the Marmaduke family, comprising             
          Hastings employees and a qualified employee benefit plan covering           








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011