-3-
shall be determined by reference to an agreed formula that takes
into account the value of the Kohler stock we determine.
We are also asked to decide whether each petitioner is
liable for the accuracy-related penalty. The parties have
resolved all other issues.
The estate reported on the estate tax return that the Kohler
stock it owned was worth $47,009,625 on the alternate valuation
date. Respondent determined that the Kohler stock the estate
owned was worth $144.5 million on the alternate valuation date.
We hold that the fair market value of the stock the estate owned
is $47,009,625, as reported on the estate’s tax return.3 Because
we have sustained the estate’s valuation of its Kohler stock, we
accordingly also find that the estate is not liable for the
accuracy-related penalty. We also find that the petitioners in
the gift tax cases are not liable for the accuracy-related
penalty.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Herbert V. Kohler, Jr., Ruth
3The estate reported that its Kohler stock was worth
$47,009,625 on the alternate valuation date and attached an
appraisal to its return indicating the stock was worth
$47,010,000. The parties stipulated that the appraisal report
determined the stock was worth $47,009,625. The parties do not
explain this $375 discrepancy.
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