Audrey J. Walton - Page 2

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               Richard B. Covey and Jerome J. Caulfield, for petitioner.              
               Carmen M. Baerga and Marie E. Small, for respondent.                   


               NIMS, Judge:  Respondent determined a deficiency in Federal            
          gift tax against petitioner for 1993 in the amount of                       
          $4,532,776.82.  The sole issue for decision is the valuation                
          under section 2702 of gifts resulting from petitioner’s creation            
          of two grantor retained annuity trusts (GRAT’s).                            
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the year in             
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               This case was submitted fully stipulated pursuant to Rule              
          122, and the facts are so found.  The stipulations of the                   
          parties, with accompanying exhibits, are incorporated herein by             
          this reference.  At the time the petition was filed in this case,           
          petitioner resided in Versailles, Missouri.                                 
               Prior to April 7, 1993, petitioner was the sole owner of,              
          and held in her name, 7,223,478 shares of common stock of Wal-              
          Mart Stores, Inc., a publicly traded entity.  Then, on April 7,             
          1993, petitioner established two substantially identical GRAT’s,            
          each of which had a term of 2 years and was funded by a transfer            

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