Estate of Mary D. Maggos - Page 2

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          for decision is whether a transaction in which Mary D. Maggos’              
          shares of stock in a family-owned company were redeemed                     
          constitutes a taxable gift by Mary D. Maggos for purposes of                
          section 2512.1                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The original petition in this case was filed on behalf of Mary D.           
          Maggos, who at the time resided in Honolulu, Hawaii.  Mary D.               
          Maggos (decedent) died on September 3, 1996, at the age of 89.              
               During 1987, Pepsi-Cola Alton Bottling, Inc. (PCAB), was an            
          Illinois corporation engaged in the business of operating a                 
          Pepsi-Cola bottling franchise in southwestern Illinois                      
          (hereinafter the franchise).  The franchise was initially                   
          acquired in 1936 by decedent’s husband, Gust Maggos.  The                   
          franchise was subsequently incorporated as PCAB.  Until his death           
          in June 1954, Gust Maggos supervised and directed the business              
          affairs of PCAB on a day-to-day basis.  During the course of                
          their marriage, Gust and decedent had two children, Nikita Maggos           
          and Catherine M. Adkins.  Subsequent to Gust Maggos’ death,                 
          Nikita Maggos assumed control of the business on a day-to-day               

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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