- 2 - Josephine T. Thompson and a $7,164,163 accuracy-related penalty under section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect on May 2, 1998, the date of decedent’s death, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are: (1) The fair market value of 487,440 shares of the voting common stock of Thomas Publishing Co., Inc. (TPC), that were owned by decedent on her death; and (2) whether the estate is liable for the accuracy-related penalty. FINDINGS OF FACT Some of the facts have been stipulated and are so found. On May 2, 1998, the date of her death, decedent resided in New York. On May 14, 1998, Carl T. Holst-Knudsen (Holst-Knudsen), decedent’s son, and The Bank of New York were appointed by the Surrogate Court of the State of New York, County of Westchester, as co-executors of decedent’s estate. Holst-Knudsen resides in New Jersey, and The Bank of New York is headquartered in New York City. TPC is a private, closely held corporation that was formed over 100 years ago, on January 28, 1898, as a New YorkPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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