- 2 - $2,091,750 reported as its fair market value on the estate’s tax return. The sole issue for our consideration is the fair market value of Harlee International, Inc., on October 23, 1995, the date of decedent’s death. FINDINGS OF FACT1 Decedent Natalie Leichter was a resident of Los Angeles, California, at the time of her death on October 23, 1995. Decedent’s spouse, Harvey A. Leichter, died approximately 3 months earlier during July 1995. Decedent died testate and was survived by two sons, Jeffrey L. Leichter and Steven F. Leichter. Steven Leichter resided in Walnut, California, at the time the estate’s petition was filed. Among other things, the estate included all of the outstanding common stock of Harlee International, Inc. (Harlee). At the time of decedent’s death, Harlee was a California corporation which had elected S corporation status for Federal tax purposes. Harlee had 20,000 shares outstanding and was a wholesale distributor of futon frames. Harlee was founded in 1981 by Harvey Leichter. It began as a small importer and distributor of industrial fasteners imported from Asia. Initially, Harlee operated out of the Leichter residence. In the mid-1980s, Harlee entered into the business of the wholesale 1 The parties’ stipulations of facts are incorporated herein by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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