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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated April 16,
1999, respondent determined a deficiency in Federal estate tax of
$5,427,983. Of the adjustments giving rise to that
determination, the only one remaining in dispute is respondent’s
increase in the value of certain shares of stock included in the
gross estate.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect at the time of decedent’s death,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
Introduction
Richie C. Heck (decedent) died on February 15, 1995 (the
date of death or the valuation date). Gary Heck (sometimes,
petitioner) is the special administrator of decedent’s estate.
At the time of the petition, petitioner resided in Santa Rosa,
California. Among the assets includable in decedent’s gross
estate are 630 shares of stock (the shares), representing
39.62 percent, of the outstanding common stock of F. Korbel &
Bros., Inc. (Korbel), a California corporation. Petitioner
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