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1. What was the fair market value of the 22,100 shares of
stock in the Renier Company held by James J. Renier (decedent) at
his death on April 10, 1994 (valuation date).
2. Whether the estate is liable for an addition to tax
under section 6662(a) for a substantial estate or gift tax
valuation understatement.1
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect as of the date 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 and
attached exhibits. At the time of filing the petition, co-
executor Kent L. Renier resided, and co-executor Dubuque Bank &
Trust Company had its principal place of business, in Dubuque,
Iowa. Decedent resided in Dubuque, Iowa, on the date of his
death, and his will was probated in the Iowa District Court for
Dubuque County.
1 The estate also alleged in the petition that respondent
erred in disallowing a deduction by the estate for charitable
bequests totaling $12,500. However, the estate made no argument
at trial or on brief concerning that allegation, and we consider
it abandoned. See Rybak v. Commissioner, 91 T.C. 524, 566 n.19
(1988); Bowman v. Commissioner, T.C. Memo. 1997-52 n.1, affd.
without published opinion 149 F.3d 1167 (4th Cir. 1998).
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