Estate of Hall v. Commissioner
United States Tax Court
P filed a Federal estate tax return and reported its equity interest in H, a closely held corporation, at the adjusted book value of the shares as of the date of decedent's death. The shares were subject to various transfer restrictions and buy-sell agreements establishing adjusted book value as the sales price under the agreements.
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P filed a Federal estate tax return and reported its equity interest in H, a closely held corporation, at the adjusted book value of the shares as of the date of decedent's death. The shares were subject to various transfer restrictions and buy-sell agreements establishing adjusted book value as the sales price under the agreements. Based on comparisons with a number of comparable companies, P's experts determined that the adjusted book value provided a reasonable estimate of the fair market value of the shares at the valuation date. Held, R's expert erred in, among other things, ignoring the…
1Opinion of the Court
Cohen, Judge:
Respondent determined a deficiency of $201,776,276.84 in the Federal estate tax of the estate of Joyce C. Hall, deceased, Donald J. Hall, executor. After concessions, the issue for decision is the value for estate tax purposes of decedent’s equity interest in Hallmark Cards, Inc.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set forth in the stipulations are incorporated in our findings by this reference. Joyce C. Hall (decedent) died testate on October 29, 1982. At the time of his death, decedent resided in Leawood, Kansas. Decedent’s will, which named his…
2Cases cited21 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Chiu v. CommissionerUnited States Tax Court · 1985
- Messing v. CommissionerUnited States Tax Court · 1967
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
16 more not listed; retrieve them via the Exa API.
3Cited by132 opinions
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Doly v. Chang (In Re Joy Recovery Technology Corp.)United States Bankruptcy Court, N.D. Illinois · 2002
- Estate of Young v. CommissionerUnited States Tax Court · 1998
- Estate of Strangi v. CommissionerUnited States Tax Court · 2000
- Estate of True v. CommissionerCourt of Appeals for the Tenth Circuit · 2004
127 more not listed; retrieve them via the Exa API.