Damon v. Commissioner
United States Tax Court
Held, that the fair market value of common stock of a corporation held by the estate on the valuation date is the price at which other common stock of such corporation was sold in the over-the-counter market on such date. Sec. 2031, I.R.C. 1954, and sec. 20.2031-2, Estate Tax Regs.
1Opinion of the Court
OPINION
The principal issue involved concerns the valuation as of January 16, 1961, the alternate valuation date elected by the executors of the estate under section 2032 of the Internal Bevenue Code of 1954, of the common stock of Bowser owned by the decedent at the time of his death and which continued to be owned by his estate at the alternate valuation date. This consisted of 240,801% shares out of a total of 721,765 shares of Bowser common stock outstanding (of which a subsidiary of Bowser owned 87,614% shares). The stock was included in the estate tax return at a value of $3 per share.…
2Cases cited5 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. Safe Deposit & Trust Co. of BaltimoreCourt of Appeals for the Fourth Circuit · 1938
- Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Moore v. CommissionerUnited States Board of Tax Appeals · 1930
- Spencer v. CommissionerUnited States Tax Court · 1945
3Cited by14 opinions
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Ed & Jim Fleitz, Inc. v. CommissionerUnited States Tax Court · 1968
- Estate of Kopperman v. CommissionerUnited States Tax Court · 1978
- Rushton v. CommissionerUnited States Tax Court · 1973
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