Estate of Armstrong v. Comm'r
United States Tax Court
In 1991 and 1992, D gave stock to Cs and other donees. For gift tax purposes, D valued the stock at $ 100 per share. As a condition of receiving certain of these gifts, Cs agreed to pay additional gift taxes arising if the gifts of stock were later determined to have a fair market value greater than $ 100 per share. In 1993, D died.
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In 1991 and 1992, D gave stock to Cs and other donees. For gift tax purposes, D valued the stock at $ 100 per share. As a condition of receiving certain of these gifts, Cs agreed to pay additional gift taxes arising if the gifts of stock were later determined to have a fair market value greater than $ 100 per share. In 1993, D died. Subsequently, R determined that D's gifts of stock should be valued at $ 109 per share, resulting in gift tax deficiencies which were paid by a trust that D had established. The total gift taxes paid on D's 1991 and 1992 gifts of stock were $ 4,680,284. Cs paid…
1Opinion of the Court
OPINION
Thornton, Judge:
Respondent determined a $2,350,071 Federal estate tax deficiency with respect to the Estate of Frank Armstrong, Jr. (the estate). This case is before us on respondent’s motion for partial summary judgment under Rule 121.1 Respondent seeks summary judgment upon the following issues: (1) Whether gift taxes of $4,680,284 paid by or on behalf of Frank Armstrong, Jr. (decedent), on gifts made wdthin 3 years of his death are includable in his gross estate; (2) whether decedent received partial consideration for the gifts so as to reduce the gifts’ value and consequently the…
2Cases cited54 opinions
- Dandridge v. WilliamsSupreme Court of the United States · 1970
- Weinberger v. SalfiSupreme Court of the United States · 1975
- Federal Communications Commission v. Beach Communications, Inc.Supreme Court of the United States · 1993
- Reno v. FloresSupreme Court of the United States · 1993
- Duke Power Co. v. Carolina Environmental Study Group, Inc.Supreme Court of the United States · 1978
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3Cited by11 opinions
- McCord v. Comm'rUnited States Tax Court · 2003
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- Estate of Ackerley v. Department of RevenueWashington Supreme Court · 2017
- Charles T. McCord, Jr. and Mary S. McCord, Donors v. CommissionerUnited States Tax Court · 2003
- Estate of Ackerley v. Dep't of RevenueWashington Supreme Court · 2017
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