Grantham v. State of Tennessee Board of Equalization

*172OPINION

CANTRELL, Judge.

Daniel I. Perlberg’s executor has appealed the State Board of Equalization’s valuation, for inheritance tax purposes, of the stock in United Liquors of Chattanooga, Inc., a closely held corporation. The controversy is whether the stock’s value is affected by a binding agreement allowing another shareholder or the corporation to purchase the stock at book value. We hold that under the facts of this case, the market value of the stock should be included in the decedent’s estate.

I

In May of 1963, Sidney Perlberg granted to his brother Daniel an option to purchase, at…