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MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined a Federal estate tax
deficiency of $2,354,521 with respect to the Estate of George C.
Blount (the estate). After concessions, the issue remaining for
decision is the value for Federal estate tax purposes of
43,079.9657 shares of Blount Construction Co. (BCC) owned by
George C. Blount (decedent) on September 21, 1997, his date of
death and the valuation date. Subsumed within that issue is the
question of whether a buy-sell agreement covering the BCC shares
fixes their value, or whether the agreement should be disregarded
in determining that value.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the date of decedent’s death,
and all 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. We
incorporate by this reference the stipulation of facts and the
accompanying exhibits.
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