Estate of Frank Armstrong, Jr., Frank Armstrong III v. Commissioner

119 T.C. No. 13

UNITED STATES TAX COURT ESTATE OF FRANK ARMSTRONG, JR., DECEASED, FRANK ARMSTRONG III, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1118-98. Filed October 29, 2002. In 1991 and 1992, D gave stock to Cs and other donees. For gift tax purposes, D valued the stock at $100 per share. As a condition of receiving certain of these gifts, Cs agreed to pay additional gift taxes arising if the gifts of stock were later determined to have a fair market value greater than $100 per share. In 1993, D died. Subsequently, R determined that D’s gifts of stock…