- 2 - 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.Page: Previous 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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