Estate of Armstrong v. Comm'r
United States Tax Court
In 1991 and 1992, D gave stock to Cs and other donees. For gift tax purposes, D valued the stock at $ 100 per share. As a condition of receiving certain of these gifts, Cs agreed to pay additional gift taxes arising if the gifts of stock were later determined to have a fair market value greater than $ 100 per share. In 1993, D died.
Read the full summary
In 1991 and 1992, D gave stock to Cs and other donees. For gift tax purposes, D valued the stock at $ 100 per share. As a condition of receiving certain of these gifts, Cs agreed to pay additional gift taxes arising if the gifts of stock were later determined to have a fair market value greater than $ 100 per share. In 1993, D died. Subsequently, R determined that D's gifts of stock should be valued at $ 109 per share, resulting in gift tax deficiencies which were paid by a trust that D had established. The total gift taxes paid on D's 1991 and 1992 gifts of stock were $ 4,680,284. Cs paid…
1Opinion of the Court
ESTATE OF FRANK ARMSTRONG, JR., DECEASED, FRANK ARMSTRONG III, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Armstrong v. Comm'r
No. 1118-98
United States Tax Court
119 T.C. 220; 2002 U.S. Tax Ct. LEXIS 50; 119 T.C. No. 13;
October 29, 2002, Filed
Respondent's motion for partial summary judgment granted.
In 1991 and 1992, D gave stock to Cs and other donees. For gift
tax purposes, D valued the stock at $ 100 per share. As a
condition of receiving certain of these gifts, Cs agreed to pay
additional gift taxes arising if the gifts of stock were later
determined to have a…
2Cases cited57 opinions
- Dandridge v. WilliamsSupreme Court of the United States · 1970
- Weinberger v. SalfiSupreme Court of the United States · 1975
- Federal Communications Commission v. Beach Communications, Inc.Supreme Court of the United States · 1993
- Reno v. FloresSupreme Court of the United States · 1993
- Duke Power Co. v. Carolina Environmental Study Group, Inc.Supreme Court of the United States · 1978
52 more not listed; retrieve them via the Exa API.