Coblentz v. Commissioner (In re Estate of McClatchy)
United States Tax Court
Decedent owned shares of stock that before his death were subject to certain securities law restrictions adversely affecting the value of the shares. The restrictions were not applicable to the shares in the hands of decedent's personal representatives, so that the per share value automatically increased from $ 12.3375 to $ 15.56 at decedent's death.
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Decedent owned shares of stock that before his death were subject to certain securities law restrictions adversely affecting the value of the shares. The restrictions were not applicable to the shares in the hands of decedent's personal representatives, so that the per share value automatically increased from $ 12.3375 to $ 15.56 at decedent's death. Held: the per share value for Federal estate tax purposes is $ 15.56, since that was the value at the "moment" of decedent's death. Ahmanson Foundation v. United States, 674 F.2d 761 (9th Cir. 1981), applied; United States v. Land, 303 F.2d 170…
1Opinion of the Court
OPINION
Nims, Judge:
In this case, respondent determined a $5,784,910 Federal estate tax deficiency and a $1,156,982 addition to tax under section 6662(b)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at decedent’s date of death, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the sole remaining issue for decision is whether certain securities law restrictions that applied to shares of stock of McClatchy Newspapers, Inc. (the company), owned by decedent during his lifetime, but which became…
2Cases cited8 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
- United States v. LandCourt of Appeals for the Fifth Circuit · 1962
3 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Charles K. McClatchy William K. Coblentz and James McClatchy Personal Representatives v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- Coblentz v. Commissioner (In re Estate of McClatchy)United States Tax Court · 1996
- Estate of Charles K. McClatchy William K. Coblentz and James McClatchy Personal Representatives v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- Estate of Charles K. McClatchy, William K. Coblentz and James McClatchy, Personal Representative v. CommissionerUnited States Tax Court · 1996