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.
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