Allerton J. McEwan v. Commissioner of Internal Revenue

The issue on appeal is whether the Tax Court’s finding as to the fair market value of the stock at the time of its acquisition in 1937 was clearly erroneous.

In 1937 taxpayer inherited from his grandfather 87% shares of stock of McEwan Brothers, a closely held family corporation in the business of manufacturing paperboard. He also acquired on or about the day of his grandfather’s death 1% shares from his brother and 1 share from his mother. For federal estate tax purposes, the stock was valued at $177.70 per share after the executors of petitioner’s grandfather had contested a higher…