Rushton v. Commissioner
United States Tax Court
Petitioners transferred as gifts shares of corporate stock to several donees on various dates and claimed blockage discount from the mean between the bid and asked prices from over-the-counter quotations. Petitioners contend that all shares transferred to all donees on the same date constitute a single block of stock for purposes of applying the blockage discount.
Read the full summary
Petitioners transferred as gifts shares of corporate stock to several donees on various dates and claimed blockage discount from the mean between the bid and asked prices from over-the-counter quotations. Petitioners contend that all shares transferred to all donees on the same date constitute a single block of stock for purposes of applying the blockage discount. Held, each gift must be valued separately and only the impact on the market of the number of shares of each gift shall be considered in applying the blockage discount. Maytag v. Commissioner, 187 F. 2d 962 (C.A. 10, 1951), not…
1Opinion of the Court
Goite, Judge:
Respondent determined the following deficiencies in Federal gift tax:
Docket No. Petitioner Year Deficiency 7770-70.William J. Rushton. 1966 $984.37 7770-70..William J. Rushton. 1967 893.26 7771-70.Elizabeth P. Rushton 1. 1966 984.38 7771-70.Elizabeth P. Rushton 1. 1967 866.26
Petitioner in docket No. 7770-70 claims an overpayment of tax for the taxable year 1966 in the amount of $76.76 and petitioners in docket No. 7771-70 claim an overpayment of tax for the taxable year 1966 in the amount of $58.32.
Upon joint motion of all the parties, these cases were consolidated for trial,…
2Cases cited10 opinions
- L. K. Peterson and William H. Scott, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Phipps v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1942
- Maytag v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Phipps v. CommissionerUnited States Board of Tax Appeals · 1941
5 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Piper v. CommissionerUnited States Tax Court · 1979
- Shepherd v. CommissionerUnited States Tax Court · 2000
- Calder v. CommissionerUnited States Tax Court · 1985
- Frizzelle Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Estate of Friedberg v. CommissionerUnited States Tax Court · 1992
13 more not listed; retrieve them via the Exa API.