In re the Appraisal Under the Transfer Tax Law of the Estate of Kerr

Slater, S.

The question involved in this matter relates to the value of shares of closely held stock in the corporation of Folwell Brother & Company of Philadelphia. The State Tax Commission has appraised 400 shares of the value per share of $219.89. The executors contend the fair market value is $165 , per share, based upon sales. The State contends that the cases of Matter of Dupignac (123 Misc. 21, opinion by this court; affd., 211 App. Div. 862) and Matter of Jackson (by Surrogate Foley, 125 Misc. 787) support their theory of appraisement on actual value from the financial statements of…