Estate of Piper v. Commissioner
United States Tax Court
Donor made a gift of all the issued and outstanding stock of two investment corporations. These corporations, the donor, and members of the donor's family owned shares constituting a substantial block of the issued and outstanding stock of another corporation (PAC), whose shares were listed and traded on the New York Stock Exchange. The stock of the two investment companies and the PAC stock held by them were unregistered.
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Donor made a gift of all the issued and outstanding stock of two investment corporations. These corporations, the donor, and members of the donor's family owned shares constituting a substantial block of the issued and outstanding stock of another corporation (PAC), whose shares were listed and traded on the New York Stock Exchange. The stock of the two investment companies and the PAC stock held by them were unregistered. Held, based on all the circumstances, for gift tax purposes: 1. Donor was a "control person" of PAC within the meaning of the Securities Act of 1933 and, as such, could…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency in William T. Piper, Sr.’s gift tax for 1969 in the amount of $411,839.57. The only issue for decision is the valuation of all the outstanding stock of two investment companies which was the subject of gifts from William T. Piper, Sr., to his son and to 11 trusts for the benefit of his grandchildren.
FINDINGS OF FACT
Some of the facts were stipulated and are found accordingly. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference.
William T. Piper, Sr. (Piper), died on January 15, 1970. His estate…
2Cases cited25 opinions
- Securities & Exchange Commission v. Ralston Purina Co.Supreme Court of the United States · 1953
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Messing v. CommissionerUnited States Tax Court · 1967
- United States v. James E. Corr, Iii, and Roger DrayerCourt of Appeals for the Second Circuit · 1976
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3Cited by53 opinions
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
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- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
- Ward v. CommissionerUnited States Tax Court · 1986
- Irene Eisenberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
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