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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect on the date of decedent’s
death.
The only issue for decision is the fair market value of
3,601,267 restricted shares of the common stock of Reliance Steel
and Aluminum Company, a publicly traded New York Stock Exchange
company (Reliance).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Background
Decedent was predeceased by her husband, William Gimbel
(William), who died on December 9, 1998. Decedent died on
June 5, 2000 (the valuation date), while residing in California.
From the time of her death, decedent’s three children,
Thomas W. Gimbel (Thomas), Janet G. Rogers, and Joanne M. Gimbel,
have served as coexecutors and cotrustees of decedent’s estate,
and each has resided in California.
Reliance was founded in 1939 by William’s uncle, Thomas
Neilan (Mr. Neilan). In 1947, Reliance hired William as an
employee. In the late 1950s, Mr. Neilan died, and upon his death
William received from Mr. Neilan’s estate a 4-percent common
stock interest in Reliance, and William became Reliance’s chief
executive officer.
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Last modified: May 25, 2011