Estate of H.A. True, Jr. - Page 10




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               3.  Did Jean True make gift loans when she transferred                 
          interests in the True companies to her sons in exchange for                 
          interest-free payments received approximately 90 days after the             
          effective date of the transfers (gift loan issue); and                      
               4.  Are petitioners liable for valuation understatement                
          penalties under section 6662(a), (g), and (h) (penalty issue)?              
               We hold in respondent’s favor that the buy-sell agreements             
          do not control estate and gift tax values.  We value the subject            
          interests at amounts greater than the prices paid under the buy-            
          sell agreements and hold that understatement penalties apply to             
          parts of the resulting deficiencies.  We hold for respondent on             
          the gift loan issue.                                                        
               For convenience and clarity, findings of fact and opinion              
          are set forth separately under each issue.  The findings of fact            
          regarding any issue incorporate, by this reference, the facts as            
          found with respect to any issue previously addressed.                       
          Issue 1.  Does Book Value Price Specified in Buy-Sell Agreements            
          Control Estate and Gift Tax Values of Subject Interests in True             
          Companies?                                                                  
                                  FINDINGS OF FACT                                    
              Some of the facts have been stipulated by the parties and               
          are so found.  The stipulation of facts, supplemental stipulation           
          of facts, associated exhibits, and oral stipulations are                    
          incorporated by this reference.                                             








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