Estate of Lee v. Commissioner
United States Tax Court
At the time of her death, decedent and her husband held as community property under Washington State law 80 percent of the outstanding shares of common stock and 100 percent of the outstanding shares of preferred stock in a closely held corporation. Decedent bequeathed her interest in the common stock to her husband and her interest in the preferred stock to charity.
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At the time of her death, decedent and her husband held as community property under Washington State law 80 percent of the outstanding shares of common stock and 100 percent of the outstanding shares of preferred stock in a closely held corporation. Decedent bequeathed her interest in the common stock to her husband and her interest in the preferred stock to charity. Held, the fair market value of decedent's interest in the corporation determined as a minority interest of 40 percent of the outstanding common shares and 50 percent of the outstanding preferred shares. Held, further, the fair…
1Opinion of the Court
Dawson, Judge:
Respondent determined deficiencies in the Federal estate and gift taxes of the Estate of Elizabeth M. Lee in the amounts $1,924,902.71 and $87,075 respectively. Concessions were made by the parties. The two issues that remain for our decision relate to the estate tax deficiency. They are:(1) What was the fair market value on September 14,1971, of decedent’s interest in the 4,000 shares of common stock and the 50,000 shares of preferred stock in F. W. Palin Trucking, Inc., which shares were owned by her and her husband as community property under the law of Washington State.(2)…
2Cases cited7 opinions
- Humes v. United StatesSupreme Court of the United States · 1928
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Yiatchos v. YiatchosSupreme Court of the United States · 1964
- LaHue v. Keystone Investment Co.Court of Appeals of Washington · 1972
- In Re Estate of PattonCourt of Appeals of Washington · 1972
2 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- The Estate of Mary Frances Smith Bright, Deceased, by H. R. Bright, Independent v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
- Ward v. CommissionerUnited States Tax Court · 1986
- Northern Trust Co. v. CommissionerUnited States Tax Court · 1986
17 more not listed; retrieve them via the Exa API.