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MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies in
petitioners’ Federal estate and gift taxes for 1998 and accuracy-
related penalties under section 6662(a)2 in the following
amounts:
Sec. 6662(a)
Accuracy-Related
Petitioner Deficiency Penalty
Herbert V. Kohler, Jr. $416,550.23 $83,310.05
Ruth DeYoung Kohler 393,367.41 78,673.48
Estate of Frederic C.
Kohler, Deceased, Natalie A.
Black, Personal
Representative 53,650,374.00 10,723,941.40
Natalie A. Black 371,058.85 74,211.77
We are asked to decide the fair market value of stock of the
Kohler Co. (Kohler or the company) owned by the estate of
Frederic C. Kohler (the estate) on the alternate valuation date.
The parties stipulated that the value of the Kohler stock at
issue in the related gift tax cases shall be calculated by
reference to the value of the Kohler stock we determine in the
estate tax case. The parties have also agreed that the per share
value for the different classes of Kohler stock in each case
2All section references are to the Internal Revenue Code,
and all Rule references are to the Tax Court Rules of Practice
and Procedure, unless otherwise indicated.
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Last modified: May 25, 2011