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