Estate of George C. Blount, Deceased, Fred B. Aftergut, Executor - Page 4

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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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