- 9 - Specialty for the fiscal years ending January 31, 1949 through 1952, are as follows: Fiscal Year Ending January 31 (In Thousands) 1949 1950 1951 1952 Assets $452 $405 $385 $432 Earned surplus 120 103 127 148 Sales 742 644 593 677 Net income 35 6 24 21 On his 1948 gift tax return, Joseph valued the JM common stock at $1.86 per share. On his 1950 gift tax return, Joseph valued the JM common stock between $1.98 and $2.25 per share. On his 1949 gift tax return, Cyril valued the JM common stock at $2.25 per share and the JM preferred stock at $.90 per share as of December 24, 1949. Cyril’s 1949 gift tax return was not filed until 1957, and it acknowledged that the values were in line with the stock values determined in connection with the settlement of Joseph’s estate. Joseph died on April 29, 1953. Joseph’s estate tax return included the value of JM and Specialty stock as follows: Stock Per-Share Value 18,158 shares JM subject to option at $1 per share $1.00 33,490 shares JM, common 1.50 21,464 shares JM, preferred .90 112-1/2 shares Specialty, common 150.00 25,000 shares Specialty, preferred .90 The IRS estate tax examiner proposed certain adjustments to Joseph’s taxable estate, including an increase in the per-sharePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011