Tebb v. Commissioner
United States Tax Court
1. Held, respondent's determination of the fair market value of closely held corporate stock sustained. 2. For many years prior to his death, decedent had often expressed his intention of bequeathing the majority of his stock in a closely held corporation to his two sons. In order that there would be no controversy concerning the stock after his death with his widow, he deposited the shares in escrow under a letter agreement with the sons.
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1. Held, respondent's determination of the fair market value of closely held corporate stock sustained. 2. For many years prior to his death, decedent had often expressed his intention of bequeathing the majority of his stock in a closely held corporation to his two sons. In order that there would be no controversy concerning the stock after his death with his widow, he deposited the shares in escrow under a letter agreement with the sons. Upon decedent's death, the escrow agent delivered the shares to the sons. In the estate tax return the book value of such shares was included in the…
1Opinion of the Court
Rice, Judge:
This proceeding involves the following deficiencies in tax:
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The issues to be decided are: (1) Whether the respondent erred in his determination of the fair market value of certain closely held corporate common stock, owned by decedent, Thomas W. Tebb, at the time of his death; (2) whether the shares of such stock, which were received by petitioners, Fred R. and Neal A. Tebb, upon decedent’s death, constituted taxable income to them; and (3) whether petitioner estate was entitled to the marital deduction as claimed by it on the estate tax return for the interest in…
2Cases cited4 opinions
- Estate of Edward F. Pipe, Deceased, Nettie M. Pipe v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Pipe v. CommissionerUnited States Tax Court · 1954
- Goetchius v. CommissionerUnited States Tax Court · 1951
- Estate of Melamid v. CommissionerUnited States Tax Court · 1954
3Cited by11 opinions
- Davenport v. CommissionerUnited States Tax Court · 1962
- South Carolina National Bank v. McLeodDistrict Court, D. South Carolina · 1966
- Schroeder v. United StatesDistrict Court, W.D. Oklahoma · 1988
- Andrews v. CommissionerUnited States Tax Court · 1976
- Natkanski v. CommissionerUnited States Tax Court · 1992
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