John E. Wall - Page 2




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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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