McNary v. Commissioner
United States Tax Court
Held, determination of the fair market value of securities in an estate for estate tax purposes was properly made by respondent by arriving at the average of the means of quoted over-the-counter bid and ask prices for the last business day prior and the first business day subsequent to a Sunday which was the evaluation date for such property in petitioner estate.
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Held, determination of the fair market value of securities in an estate for estate tax purposes was properly made by respondent by arriving at the average of the means of quoted over-the-counter bid and ask prices for the last business day prior and the first business day subsequent to a Sunday which was the evaluation date for such property in petitioner estate. Held, further, that where dividends had been declared prior to the death of decedent payable subsequent thereto and the security was on the date of death selling ex-dividend, respondent properly increased the fair market value of…
1Opinion of the Court
Wtthey, Judge:
A deficiency has been determined by the Commissioner in the estate tax of the Estate of Hattie L. McNary in the amount of $1,798.45.
The issues to be decided are (1) whether respondent has erred in valuing securities in the estate which were traded on the over-the-counter market on the basis of the average of the means of the quoted bona fide bid and ask prices and (2) whether the value of such stocks selling ex-dividend on the valuation date was properly increased by the amount of the respective dividends pertaining thereto. Other issues which have been settled by the parties…
2Cases cited2 opinions
- Spencer v. CommissionerUnited States Tax Court · 1945
- Lockie v. CommissionerUnited States Tax Court · 1953
3Cited by16 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Gilford v. CommissionerUnited States Tax Court · 1987
- Walter L. Gross, Jr. And Barbara H. Gross (99-2239) Calvin C. Linnemann and Patricia G. Linnemann (99-2257) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2001
- Duncan Industries, Inc., etc. v. CommissionerUnited States Tax Court · 1979
- Estate of Rowan v. CommissionerUnited States Tax Court · 1970
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