Estate of Reynolds v. Commissioner
United States Tax Court
Decedents and their family owned virtually all of the units in a voting trust which held a majority of the shares of a stock life insurance company. Under the terms of the voting trust the units could not be sold unless they were first offered to the other holders of units at a formula price based upon the dividends distributed by the company.
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Decedents and their family owned virtually all of the units in a voting trust which held a majority of the shares of a stock life insurance company. Under the terms of the voting trust the units could not be sold unless they were first offered to the other holders of units at a formula price based upon the dividends distributed by the company. If the other unit holders refused the offer, the units would have to be offered a second time to the company's board of directors at the same formula price. The units could be gifted or devised but in the hands of any donee or devisee remained subject…
1Opinion of the Court
Forrester, Judge:
Eespondent has determined deficiencies in petitioners’ estate and gift taxes and has also made additions to those taxes pursuant to section 6651(a) of the Internal Kevenue Code of 1954 and section 291(a) of the Internal Kevenue Code of 19392 for the years indicated as follows:
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Tbe proceedings have been consolidated because the principal issue in each docket is whether respondent erred in determining the fair market value for estate and gift tax purposes of certain voting trust certificates.
Concessions having been made, the only other issues that remain for…
2Cases cited53 opinions
- Helvering v. SalvageSupreme Court of the United States · 1936
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Clark v. CommissionerUnited States Tax Court · 1952
- United States v. LandCourt of Appeals for the Fifth Circuit · 1962
48 more not listed; retrieve them via the Exa API.
3Cited by77 opinions
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Harwood v. CommissionerUnited States Tax Court · 1984
- Ward v. CommissionerUnited States Tax Court · 1986
- Diamond v. CommissionerUnited States Tax Court · 1971
- Kolom v. Comm'rUnited States Tax Court · 1978
72 more not listed; retrieve them via the Exa API.