Estate of Jephson v. Commissioner
United States Tax Court
Decedent owned all the stock of two investment companies on the date of her death. The assets of both companies consisted solely of cash and marketable securities. Held, the value of the stock of each investment company is its net asset value reduced by the cost of liquidation.
1Opinion of the Court
JACOBS, Judge:
By statutory notice of deficiency, respondent determined a deficiency of $847,458.38 in estate tax due from the Estate of Lucretia Davis Jephson, deceased. In his amended answer, respondent claimed a $263,655.19 increased deficiency; thus the total amount in controversy is $1,111,113.57.
After concessions, the only matter left for determination is the value of all the outstanding stock of two investment companies, R.B. Davis Investment Co. and Davis Jephson Finance Co., owned by Lucretia Davis Jephson at her death.
FINDINGS OF FACT
Some of the facts have been stipulated and are so…
2Cases cited5 opinions
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Harwood v. CommissionerUnited States Tax Court · 1984
- Estate of Piper v. CommissionerUnited States Tax Court · 1979
- De Guebriant v. CommissionerUnited States Tax Court · 1950
- Claflin v. CommissionerCourt of Appeals for the Second Circuit · 1951
3Cited by8 opinions
- Estate of Ford v. CommissionerUnited States Tax Court · 1993
- Estate of Luton v. CommissionerUnited States Tax Court · 1994
- Estate of Bennett v. CommissionerUnited States Tax Court · 1993
- Lefrak v. CommissionerUnited States Tax Court · 1993
- Estate of Dougherty v. CommissionerUnited States Tax Court · 1990
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