Estate of Andrews v. Commissioner
United States Tax Court
Held, values are determined for stock held by decedent in closely held family corporations. Held, further, in arriving at these values, discounts are applied for lack of control and marketability even though decedent and his siblings held all the stock in the corporations.
1Opinion of the Court
OPINION
Whitaker, Judge-.
Respondent determined a deficiency of $160,981.67 in the Federal estate tax of petitioner. The sole issue for decision is the date-of-death fair market value of shares of stock held by decedent in four closely held corporations. Since this case is largely factual, we have combined our findings of fact with our opinion.
Some of the facts have been stipulated and are so found. The parties have stipulated that Woodbury G. Andrews (hereinafter referred to as the decedent) was a resident of Excelsior, Minn., when he died testate on May 16, 1975. It has been further…
2Cases cited25 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
- 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
- Raul Llorente v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
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3Cited by155 opinions
- The Sommers Drug Stores Co. Employee Profit Sharing Trust, Cross-Appellant v. Corrigan Enterprises, Inc. And Walter N. Corrigan, Cross-AppelleesCourt of Appeals for the Fifth Circuit · 1986
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Minahan v. CommissionerUnited States Tax Court · 1987
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
150 more not listed; retrieve them via the Exa API.