Messing v. Commissioner
United States Tax Court
Petitioners made gifts of shares of stock representing a minority interest in a closely held corporation in September 1961, at which time the stock was not publicly traded. Petitioners valued the gifted shares at $ 10 per share, based principally on sales to third parties at the same price in the summer of 1961. In January 1962, the stock of the corporation was offered to the public at $ 36.66 per share.
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Petitioners made gifts of shares of stock representing a minority interest in a closely held corporation in September 1961, at which time the stock was not publicly traded. Petitioners valued the gifted shares at $ 10 per share, based principally on sales to third parties at the same price in the summer of 1961. In January 1962, the stock of the corporation was offered to the public at $ 36.66 per share. Respondent valued the gifted shares at $ 30 per share, using the public offering price as a starting point and applying certain discount factors. On that basis, respondent also claimed, in an…
1Opinion of the Court
Morris M. Messing, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Helen F. Messing, Deceased, Morris M. Messing, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Messing v. Commissioner
Docket Nos. 5865-65, 6295-65
United States Tax Court
48 T.C. 502; 1967 U.S. Tax Ct. LEXIS 76;
June 29, 1967, Filed
Decisions will be entered under Rule 50.
Petitioners made gifts of shares of stock representing a minority interest in a closely held corporation in September 1961, at which time the stock was not publicly traded. Petitioners valued the gifted shares at $ 10 per…
2Cases cited20 opinions
- Messing v. CommissionerUnited States Tax Court · 1967
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- Commissioner of Internal Revenue v. MarshallCourt of Appeals for the Second Circuit · 1942
- Jacoby v. . JacobyNew York Court of Appeals · 1907
- Herr v. CommissionerUnited States Tax Court · 1961
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