Citizens Fidelity Bank & Trust Co. v. Reeves

COMBS, Justice.

This appeal involves the relative merits of the “blockage” rule and the “unit” rule' in the assessment of shares of stock for inheritance tax purposes.

James P. Bogler died November 10, 1949, the holder of 3,000 shares of class “A” common stock and 27,000 shares of class “B” common stock in the Glenmore Distilleries. On the day Mr. Bolger died 300 shares of Glenmore Distilleries common stock were sold on the New York Curb Stock Exchange at a price range between $10.675 and $10.75 per share. The assessment for inheritance tax purposes by the State Tax Commission was based solely…