Estate of Gilford v. Commissioner
United States Tax Court
Decedent was the largest single shareholder of G company on the date of his death, owning 381,150 shares, or about 23 percent. This stock was restricted stock under the Federal securities laws. Approximately 6 months after decedent's death, P agreed to sell its block of G company stock to C company for $ 24 per share pursuant to a merger of G and C company. Held, the fair market value of the shares for Federal estate tax purposes determined.
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Decedent was the largest single shareholder of G company on the date of his death, owning 381,150 shares, or about 23 percent. This stock was restricted stock under the Federal securities laws. Approximately 6 months after decedent's death, P agreed to sell its block of G company stock to C company for $ 24 per share pursuant to a merger of G and C company. Held, the fair market value of the shares for Federal estate tax purposes determined. Held, further: In the absence of actual selling prices, the mean of the bona fide bid and asked prices of over-the-counter stock on the date of death is…
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined a deficiency of $4,330,651.21 in the Federal estate tax of the Estate of Saul R. Gilford. After concessions, the sole issue for decision is the date of death fair market value of 381,150 shares of Gilford Instrument Laboratories, Inc., common stock owned by Saul R. Gilford at his death.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts, the supplemental stipulations of fact, and attached exhibits are incorporated herein by this reference.
Petitioner is the Estate of Saul R. Gilford. On November 17,…
2Cases cited44 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- United States v. CartwrightSupreme Court of the United States · 1973
39 more not listed; retrieve them via the Exa API.
3Cited by106 opinions
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Walter L. Gross, Jr. And Barbara H. Gross (99-2239) Calvin C. Linnemann and Patricia G. Linnemann (99-2257) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2001
- Estate of Jung v. CommissionerUnited States Tax Court · 1993
- Frazee v. CommissionerUnited States Tax Court · 1992
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