Farmers National Bank & Trust Co. v. Lindley

On December 19, 1976, Porter C. McKinnon died testate. His last will and testament was- admitted to probate and Farmers National Bank & Trust Company and decedent’s son and daughter, Porter C. McKinnon, Jr. and Nancy M. Hinsdale, were appointed co-executors of the estate.

On September 19, 1977, the co-executors filed the federal and state estate tax returns for the estate. The gross estate for both federal and state purposes included nine hundred forty-two shares of ABS Industries, Inc. common stock valued at $356,656 or $368 per share.

Subsequently, the Ohio Tax Commissioner, appellee herein,…