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Inc. (Dunn Equipment), owned by Beatrice Ellen Jones Dunn
(decedent) on the date of her death, the valuation date. Unless
otherwise noted, all section references are to the Internal
Revenue Code in effect at the time of decedent’s death, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, the
supplemental stipulation of facts, and the attached exhibits.
Decedent died on June 8, 1991, at the age of 81. Jesse L.
Dunn III (Mr. Dunn), decedent’s son, is the executor of the
Estate of Beatrice Ellen Jones Dunn (estate). At the time of
filing of the petition in this case, the estate was administered
in Texas City, Texas, and Mr. Dunn resided in Dickinson, Texas.
At the time of her death, decedent owned 492,610 shares of
stock in Dunn Equipment representing 62.96 percent of the total
outstanding shares. At decedent’s death, Dunn Equipment was a
family-owned and family-operated company. Dunn Equipment used a
fiscal year ending March 31 for tax and financial reporting
purposes. Dunn Equipment was incorporated in Texas in 1949. As
of the valuation date, Dunn Equipment operated from four
locations in Texas and had approximately 134 employees, three of
whom were executives and eight of whom were salesmen. The
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