Estate of Frane v. Commissioner
United States Tax Court
In 1982, D sold to his four children equal amounts of common stock in his wholly owned corporation, S. The purchase agreement stated that the purchase price for the S stock was equal to the stock's fair market value, which was determined by appraisal to equal $ 141,050 for each block of stock sold.
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In 1982, D sold to his four children equal amounts of common stock in his wholly owned corporation, S. The purchase agreement stated that the purchase price for the S stock was equal to the stock's fair market value, which was determined by appraisal to equal $ 141,050 for each block of stock sold. Pursuant to the purchase agreement, D and each of his children executed a promissory note in the principal amount of $ 141,050, payable in 20 annual installments, with interest payable annually at a rate of 12 percent on any unpaid principal. Each promissory note contained a provision that unless…
1Opinion of the Court
Estate of Robert E. Frane, Deceased, Janet M. Frane, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent; Janet M. Frane and Estate of Robert E. Frane, Deceased, Janet M. Frane, Personal Representative, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Frane v. Commissioner
Docket Nos. 288-89, 21626-89
United States Tax Court
98 T.C. 341; 1992 U.S. Tax Ct. LEXIS 32; 98 T.C. No. 26;
March 31, 1992, Filed
Decisions will be entered under Rule 155.
In 1982, D sold to his four children equal amounts of common stock in his wholly owned corporation, S.…
Also in this document: Dissent.
2Cases cited28 opinions
- Bruning v. United StatesSupreme Court of the United States · 1964
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Lucas v. CommissionerUnited States Tax Court · 1972
- Graf v. CommissionerUnited States Tax Court · 1983
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