- 2 - 28, 1995, was $1,746,000, as respondent determined, or $920,800, as the estate contends. We hold that it was $1,161,705. Unless otherwise specified, section references are to the Internal Revenue Code as amended and in effect on the date of decedent’s death, and Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Decedent and the Executor Decedent, who lived in Asheville, North Carolina, died testate on September 28, 1995. When he died, he owned 178 shares of WSA voting common stock, which was 61.59 percent of its outstanding stock. Voting common stock was WSA’s only outstanding stock when decedent died. George W. Saenger, the executor of decedent’s estate, lived in Asheville, North Carolina, when the petition was filed. B. Waddell Sluder Adams & Co., Inc. 1. Insurance Business WSA has been an S corporation since the early 1970s. It has two components, a retail insurance agency and a managing general insurance agency (MGA). In 1995, the retail agency generated 5 percent of WSA’s revenue, and the MGA generated 95 percent. The retail agency sells insurance to the public.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011