- 25 - To this amount, Mr. Hitchner added $3,046,823 of insurance proceeds on decedent’s life13 to yield a value of approximately $10 million for 100 percent of BCC’s shares. Multiplying this amount by decedent’s 83.2-percent interest in BCC resulted in a corresponding value of $8,360,000 (rounded) for decedent’s 43,080 BCC shares, as of the valuation date. Like Mr. Fodor, Mr. Hitchner did not apply any discounts or premiums in valuing decedent’s block of shares. OPINION I. Effectiveness of the Buy-Sell Agreement Federal estate tax is imposed on the transfer of a U.S. citizen’s taxable estate. Sec. 2001(a); U.S. Trust Co. v. Helvering, 307 U.S. 57, 60 (1939). The taxable estate is defined as the gross estate less prescribed deductions. See sec. 2051. The gross estate includes all property interests owned by the decedent at death; the value of the gross estate is generally the fair market value of the included property as of the valuation date, which is generally the date of death. See secs. 2031(a), 2033; sec. 20.2031-1(b), Estate Tax Regs. 13 Although described as the life insurance proceeds on decedent’s life, the figure Mr. Hitchner actually used was that for the proceeds from the policy on Mr. Jennings’s life. The insurance proceeds received on decedent’s life were $3,146,134.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011