- 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 coveringPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011