- 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-share
Page: 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