- 5 -
but two of these transactions occurred at a price per share of
$47.
In June of 1993, decedent sold 7,000 shares of his common
stock in Hastings at $47 per share. Decedent sold 2,000 of these
shares to an officer and treasurer of Western who possessed full
knowledge of the financial affairs of Hastings. In November of
1993, petitioner, who is decedent's son and president and CEO of
both Western and Hastings, sold 2,000 shares of his stock in
Hastings at $47 per share.
On June 7, 1994, petitioner timely filed decedent's Federal
estate tax return. Based on a valuation report of Gibbs, Smith &
Schwartzman, a valuation company, the fair market value of
decedent's 366,385 shares of stock in Hastings was reported on
decedent's estate tax return at $13,384,044, or $36.53 per share.
On audit, based largely on the transactions in Hastings
stock that occurred in 1993, respondent determined that the total
fair market value of decedent's shares of stock in Hastings was
$17,220,095, or $47 per share. Based thereon, respondent
determined an increase in the value of decedent's gross estate of
$3,836,050.
OPINION
For Federal estate tax purposes, property is generally
included in a gross estate at its fair market value on the date
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011