T.C. Memo. 2001-75 UNITED STATES TAX COURT JOHN E. WALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent JOANNE WALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1590-98, 1850-98. Filed March 27, 2001. These are gift tax valuation cases in which the transferred property is nonvoting common stock of a family corporation given by petitioners to 20 trusts for their 10 children. The value per share determined by the statutory notices exceeded the value claimed in the gift tax returns by only 17 percent. The reports prepared by the experts for trial came up with values that widened the gap between the parties’ initial positions. In Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 451-452 (1980), the Court suggested that valuation cases should be settled, and warned the parties that in some cases the Court might be persuaded to adopt the position of one party, rather than to split the difference between their positions; these are such cases. Held: the determination of value in the statutory notices is sustained.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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