Coblentz v. Commissioner (In re Estate of McClatchy)
United States Tax Court
Decedent owned shares of stock that before his death were subject to certain securities law restrictions adversely affecting the value of the shares. The restrictions were not applicable to the shares in the hands of decedent's personal representatives, so that the per share value automatically increased from $ 12.3375 to $ 15.56 at decedent's death.
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Decedent owned shares of stock that before his death were subject to certain securities law restrictions adversely affecting the value of the shares. The restrictions were not applicable to the shares in the hands of decedent's personal representatives, so that the per share value automatically increased from $ 12.3375 to $ 15.56 at decedent's death. Held: the per share value for Federal estate tax purposes is $ 15.56, since that was the value at the "moment" of decedent's death. Ahmanson Foundation v. United States, 674 F.2d 761 (9th Cir. 1981), applied; United States v. Land, 303 F.2d 170…
1Opinion of the Court
ESTATE OF CHARLES K. MCCLATCHY, DECEASED, WILLIAM K. COBLENTZ AND JAMES MCCLATCHY, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Coblentz v. Commissioner (In re Estate of McClatchy)
Docket No. 21876-93.
United States Tax Court
106 T.C. 206; 1996 U.S. Tax Ct. LEXIS 9; 106 T.C. No. 9;
April 3, 1996, Filed
Decision will be entered under Rule 155.
Decedent owned shares of stock that before his death were subject to certain securities law restrictions adversely affecting the value of the shares. The restrictions were not applicable to the shares in the hands of…
2Cases cited9 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
- United States v. LandCourt of Appeals for the Fifth Circuit · 1962
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