Estate of Newhouse v. Commissioner
United States Tax Court
Decedent, N, owned all of the outstanding shares of class A voting and class B nonvoting common stock in a closely held corporation, A, at his death. Other family members owned all of the outstanding shares of A's preferred stock.
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Decedent, N, owned all of the outstanding shares of class A voting and class B nonvoting common stock in a closely held corporation, A, at his death. Other family members owned all of the outstanding shares of A's preferred stock. A's corporate charter provided that the voting common stock had exclusive rights to elect the board of directors, that all three classes of stock participated pro rata in dividends declared out of earnings, that the preferred stock had a liquidation preference, and that only the common stock could vote on plans for merger. The preferred stock was authorized by…
1Opinion of the Court
WILLIAMS, Judge:
The Commissioner determined a defi* ciency in the Federal estate tax due from the estate of Samuel I. Newhouse in the amount of $609,519,855. The Commissioner also determined an addition to tax for fraud pursuant to section 6653(b)1 in the amount of $304,759,927. The Commissioner has conceded the addition to tax for fraud.
After concessions, the remaining issues for our decision are: (1) The value, for purposes of the Federal estate tax, of 10 shares of class A common stock and 990 shares of class B common stock of Advance Publications, Inc., owned by Samuel I. Newhouse, Sr.…
2Cases cited25 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. CartwrightSupreme Court of the United States · 1973
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Messing v. CommissionerUnited States Tax Court · 1967
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3Cited by174 opinions
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- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
- Martin Ice Cream Co. v. Comm'rUnited States Tax Court · 1998
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