- 24 - class A voting stock from the reported $47,700 (or $2,650 per share) to $14,435,907 (or $801,994.83 per share) and increased the value for the 3,942.048 class B nonvoting stock from the reported $10,446,427 (or $2,650 per share) to $14,134,213 (or $3,585.50 per share). These values resulted in the following determined increases to decedent's gross estate: Amount Amount Increases reported by determined by to gross the estate respondent estate 18 shares of class A voting shares $47,700 $14,435,907 $14,388,207 3,942.048 shares of class B nonvoting shares 10,446,427 14,134,213 3,687,786 Total disputed increases 18,075,993 On brief, respondent concedes that the values of decedent's class A and class B shares do not exceed $11,090,094 and $13,887,007, respectively. In addition, respondent decreased the amount of the marital deduction from the reported $15,127,237 to $1,723,437, because of (1) respondent's redetermination of the fair market value of the class A voting stock and (2) the resulting estate tax consequences which are to be borne by that portion of the estate (the residue) passing to decedent's surviving spouse. And finally, respondent determined that petitioner is liable for $7,057,554 in penalties pursuant to section 6662(a), (g), (h)(1) and (2)(C).Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011