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Rex A. Guest and Melvin L. Katten, for petitioners.
Michael F. O’Donnell and George W. Bezold, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined a $73,789 deficiency in
petitioner John E. Wall’s gift tax for calendar 1992. Respondent
also determined a $73,789 deficiency in the 1992 gift tax of Mr.
Wall’s spouse, petitioner Joanne Wall. Mrs. Wall is a party to
these consolidated cases solely because petitioners elected to
treat Mrs. Wall as the donor of one-half of the gifts Mr. Wall
made during 1992. See sec. 2513.1
The only issue for decision is the fair market value, as of
January 1, 1992, of 9,380 shares of Demco, Inc., nonvoting common
stock, which Mr. Wall gave on that date to 20 trusts for the
benefit of his children. Petitioners claimed on their gift tax
returns that the fair market value of the stock was $221.75 per
share. Respondent asserted in the statutory notices that the
correct value was $260.13 per share, approximately 17 percent
more than the value claimed by petitioners.
1 All section references are to the Internal Revenue Code in
effect for 1992, and all Rule references are to the Tax Court
Rules of Practice and Procedure, unless otherwise specified.
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