Legal Opinion

Estate of Frane v. Commissioner

United States Tax Court

Decided March 31, 1992No. Docket Nos. 288-89, 21626-89PublishedCited by 10 opinions

In 1982, D sold to his four children equal amounts of common stock in his wholly owned corporation, S. The purchase agreement stated that the purchase price for the S stock was equal to the stock's fair market value, which was determined by appraisal to equal $ 141,050 for each block of stock sold.

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In 1982, D sold to his four children equal amounts of common stock in his wholly owned corporation, S. The purchase agreement stated that the purchase price for the S stock was equal to the stock's fair market value, which was determined by appraisal to equal $ 141,050 for each block of stock sold. Pursuant to the purchase agreement, D and each of his children executed a promissory note in the principal amount of $ 141,050, payable in 20 annual installments, with interest payable annually at a rate of 12 percent on any unpaid principal. Each promissory note contained a provision that unless…

1Opinion of the Court

OPINION

NlMS, Chief Judge:

Petitioner in docket No. 288-89 is the Estate of Robert E. Frane, deceased (the estate), Janet M. Frane, personal representative. By statutory notice of deficiency dated October 4, 1988, respondent determined a deficiency in the Federal income tax of the estate for the fiscal year ending June 30, 1985, of $103,981.42. In an amendment to answer, respondent asserted an increase in the estate's deficiency of $6,734, for a total deficiency of $110,715.42. The increased deficiency asserted by respondent is based entirely on facts stipulated by the parties.

Petitioners in…

2Cases cited12 opinions

  1. Commissioner v. TuftsSupreme Court of the United States · 1983
  2. Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
  3. Quick Trust v. CommissionerUnited States Tax Court · 1970
  4. University Country Club, Inc. v. CommissionerUnited States Tax Court · 1975
  5. American Offshore, Inc. v. CommissionerUnited States Tax Court · 1991

7 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Frazee v. CommissionerUnited States Tax Court · 1992
  2. Fazi v. CommissionerUnited States Tax Court · 1995
  3. Matthew R. White and Jill White v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
  4. Frane v. CommissionerCourt of Appeals for the Eighth Circuit · 1993
  5. Estate of Frane v. CommissionerUnited States Tax Court · 1992

5 more not listed; retrieve them via the Exa API.

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