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MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: This case concerns the proper amounts of gift
tax that petitioners, Michael W. and Caroline P. Huber, Tabitha
A. Huber, and Hans A. and Laurel D. Huber, should pay under
section 25012 on gifts of stock in the J.M. Huber Corp. (Huber)
that they reported on their Forms 709, United States Gift Tax
Return, during the period 1997 through 2000. Huber stock was not
publicly traded, and petitioners valued their gifts on the basis
of the prices Huber used for shareholder stock transactions.
These prices were determined by an independent appraiser and used
in various transactions involving Huber stock. The controversy
stems from disagreement over whether these sales constitute
arm’s-length transactions. We hold that the transactions in
question are evidence of an arm’s-length price and support the
values petitioners set on their gifts.
FINDINGS OF FACT
Petitioners resided in New Jersey at the time of filing
their petitions.
Huber Corp.
Huber was founded in 1883 by Joseph Maria Huber (J.M.
Huber), who emigrated from Germany to New York City and started a
printing business. Huber is headquartered in Edison, New Jersey.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended.
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