Northern Trust Co. v. Commissioner
United States Tax Court
In furtherance of an "estate tax freeze" plan, after a corporate reorganization J, W, P, L, and C transferred shares of class A voting common stock and class B nonvoting common stock of CCC, a closely held company, to certain long-term trusts. C died 3 days after transferring her shares. Held: The fair market value of the shares for Federal estate and gift tax purposes determined. The value was not affected by the transfer of the stock to the trusts.
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In furtherance of an "estate tax freeze" plan, after a corporate reorganization J, W, P, L, and C transferred shares of class A voting common stock and class B nonvoting common stock of CCC, a closely held company, to certain long-term trusts. C died 3 days after transferring her shares. Held: The fair market value of the shares for Federal estate and gift tax purposes determined. The value was not affected by the transfer of the stock to the trusts. Estate of Curry v. United States, 706 F.2d 1424 (7th Cir. 1983); Ahmanson Foundation v. United States, 674 F.2d 761 (9th Cir. 1981), applied.
1Opinion of the Court
NlMS, Judge:
Respondent determined a deficiency of $154,683.45 in the Federal estate tax of petitioner, the Estate of Cecilia C. Simon.2 Respondent determined the following deficiencies in other petitioners’ Federal gift taxes:3
Docket No. Calendar quarter ending Petitioner Deficiency
21439-80 June 30, 1976 John H. Curran $131,777.60
21440-80 June 30, 1976 William Curran 131,777.60
Calendar Docket No. quarter ending Petitioner Deficiency
21441-80 June 30, 1976 Patricia A. Curran $131,777.60
21442-80 June 30, 1976 Linda R. Curran 13Í,777.60
The issue for decision is the fair market value of 6 shares…
2Cases cited14 opinions
- Weinberger v. UOP, Inc.Supreme Court of Delaware · 1983
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Messing v. CommissionerUnited States Tax Court · 1967
9 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
- Interim Healthcare, Inc. v. Spherion Corp.Superior Court of Delaware · 2005
- Estate of Jung v. CommissionerUnited States Tax Court · 1993
- Travis v. CommissionerUnited States Tax Court · 1967
28 more not listed; retrieve them via the Exa API.