- 4 - Respondent determined that the 50- and 44.069-percent blocks of stock should be valued as a 94.069-percent block. A 94.069- percent block had a date-of-death value of $4,850,000. If not aggregated, however, the 50- and 44.069-percent blocks of Ledyard stock had date-of-death values of $2,043,500 and $1,747,500, respectively. The parties submitted this case fully stipulated pursuant to Rule 122. When the petition was filed, Richard was a resident of Santa Cruz, California, and Joan was a resident of Millbrae, California. Aldo died a resident of Burlingame, California. Discussion The value of property includable in a decedent’s gross estate is generally the fair market value of such property on the decedent’s date of death. Sec. 2031(a); sec. 20.2031-1(b), Estate Tax Regs. For transfer tax purposes, the fair market value is “the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.” Sec. 20.2031-1(b), Estate Tax Regs. Respondent contends that Aldo’s testamentary GPA is essentially equivalent to outright ownership, and, as a result, the Ledyard stock held by Trust A should be aggregated, for valuation purposes, with the stock Aldo owned outright. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011