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was $1,810,000, as petitioner contends; $2,713,000, as respondent
contends; or some other amount. We hold that it was $2,150,000.
Section references are to the Internal Revenue Code as in
effect when decedent died. 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.
A. Decedent
Decedent died on February 1, 1993 (the valuation date), in
San Antonio, Texas. Her husband, William J. Klauss, predeceased
her. Decedent’s son, John G. Klauss (John Klauss), is the
independent executor of decedent’s estate. He lived in Helotes,
Texas, when he filed the petition in this case.
B. Green Light Chemical Co., Inc.
1. Formation
William J. Klauss cofounded the Klauss-White Co. in 1946.
It changed its name to the Green Light Co., Inc. (Green Light),
in 1960. He ran the company until the mid-1970's, and he died in
1982.
John Klauss worked for Green Light for 38 years. He began
running the company in the mid-1970's, and he was the chairman of
the board on February 1, 1993. He retired in 1994.
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