Du Puy v. Commissioner
United States Tax Court
1. Valuation -- Closely Held Stock. -- The fair market value of closely held stock determined. 2. Estate Tax -- State Law -- Corporate Distributions Accumulated in Trust -- Section 811 (a). -- Liquidating distributions of a wasting asset corporation accumulated in trust of which decedent was life beneficiary held not includible in the gross estate of the decedent under the provisions of section 811 (a) because the decedent was not entitled thereto under Pennsylvania law. 3.…
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1. Valuation -- Closely Held Stock. -- The fair market value of closely held stock determined. 2. Estate Tax -- State Law -- Corporate Distributions Accumulated in Trust -- Section 811 (a). -- Liquidating distributions of a wasting asset corporation accumulated in trust of which decedent was life beneficiary held not includible in the gross estate of the decedent under the provisions of section 811 (a) because the decedent was not entitled thereto under Pennsylvania law. 3. Estate Tax -- Contemplation of Death -- Section 811 (c). -- Inter vivos transfers to grandchildren in 1935 and 1938 held…
1Opinion of the Court
opinion.
Murdock, Judge:
A finding must be made of the value of minority interests in closely held stock of Morewood Realty Corporation, unaided by evidence of actual sales. The Commissioner has abandoned his determinations of higher values and now contends for a value of $2',056 per share on the valuation dates. That amount will result from dividing the stipulated fair market values of the underlying assets, less liabilities, by the number of shares outstanding. It is supported by the opinion of a witness called by the Commissioner. There is little, if any, other evidence to support it. The…
2Cases cited12 opinions
- McKeown's EstateSupreme Court of Pennsylvania · 1919
- Mallory's EstateSupreme Court of Pennsylvania · 1925
- Knox's Estate (No. 1)Supreme Court of Pennsylvania · 1937
- Hosack v. CrillSuperior Court of Pennsylvania · 1901
- Nirdlinger's Estate (No. 1)Supreme Court of Pennsylvania · 1937
7 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of Leyman v. CommissionerUnited States Tax Court · 1963
- Estate of Tompkins v. CommissionerUnited States Tax Court · 1961
- Du Puy v. CommissionerUnited States Tax Court · 1947
- Estate of Halbach v. CommissionerUnited States Tax Court · 1980
- Estate of Leyman v. CommissionerUnited States Tax Court · 1963
5 more not listed; retrieve them via the Exa API.