Estate of Maddox v. Commissioner
United States Tax Court
Decedent owned a 35.5-percent interest in an incorporated family farm. It is undisputed that, in determining the value of decedent's shares for estate tax purposes, the fair market value of the real estate of the farm could be replaced by a substantially lower value computed in accord with sec. 2032A. Held, the "value" of the shares to be included in the gross estate (based, as agreed by the parties, upon the sum of the values of the assets of the farm including that of the…
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Decedent owned a 35.5-percent interest in an incorporated family farm. It is undisputed that, in determining the value of decedent's shares for estate tax purposes, the fair market value of the real estate of the farm could be replaced by a substantially lower value computed in accord with sec. 2032A. Held, the "value" of the shares to be included in the gross estate (based, as agreed by the parties, upon the sum of the values of the assets of the farm including that of the real estate as reduced pursuant to sec. 2032A) is not the "fair market value" of the shares, and is thus not entitled to…
1Opinion of the Court
RAUM, Judge:
The Commissioner determined a deficiency in Federal estate taxes against the Estate of Frances E. Wherry Maddox in the amount of $300,900.
The decedent held a minority (35.5-percent) interest in an incorporated family farm. After certain concessions, the remaining issue is whether a 30-percent discount, otherwise applicable in determining the “fair market value” of the decedent’s minority interest in the incorporated farm, is also applicable in valuing her interest therein for inclusion in the gross estate after the value of the farm has been substantially reduced by the…
2Cases cited10 opinions
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- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
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- Estate of Cowser v. CommissionerUnited States Tax Court · 1983
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