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Jr., deceased, (docket No. 10940-97),3 reported by the Estate of
H.A. True, Jr., H.A. True, III, personal representative (estate)
by reason of H.A. True, Jr.’s death in 1994 (docket No. 3409-98),
or transferred by Jean True individually in 1994 (docket No.
3408-98) (collectively, petitioners).4 Petitioners timely filed
petitions with this Court contesting the deficiencies and
penalties and claiming a refund of whatever overpayment of estate
tax might arise from payments of administration expenses not
claimed on the estate tax return. After concessions, the
following issues are to be decided:
1. Does the book value price specified in the buy-sell
agreements control estate and gift tax values of the subject
interests in the True companies (buy-sell agreement issue);
2. If the True family buy-sell agreements do not control
values, what are the estate and gift tax values of the subject
interests (valuation issue);
3Jean True is a party to docket No. 10940-97 solely because
she elected to be treated as donor of one-half of the gifts H.A.
True, Jr. made during 1993. See sec. 2513.
4We include the estate in the collective term, petitioners,
for ease of reference only. This reference does not suggest
whether we regard the personal representatives’ residences, or
the decedent’s domicile at death, to be controlling for appellate
venue purposes under sec. 7482(b)(1). See Estate of Clack v.
Commissioner, 106 T.C. 131 (1996). The issue is not implicated
in the cases at hand because Dave True and the estate’s personal
representatives were all domiciled in the same jurisdiction
(Wyoming) at all relevant times. See infra pp. 11-12.
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