Legal Opinion

Estate of Jung v. Commissioner

United States Tax Court

Decided November 10, 1993No. Docket No. 20221-88PublishedCited by 54 opinions

Decedent owned 168,600 shares of Jung Corp. stock at her death. 1. Held, fair market value of the shares determined. Sec. 2031, I.R.C. 1954. 2. Held, further, petitioner is not liable for an addition to tax. Sec. 6660, I.R.C. 1954.

1Opinion of the Court

Chabot, Judge:

Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $2,396,902.92. By amendment to answer, respondent asserts an addition to tax of $719,070.90 under section 66601 (valuation understatement).

After concessions by both sides, the issues are as follows:(1) What the fair market value of decedent’s 168,600 shares of Jung Corp. stock was on the date of her death (Oct. 9, 1984); and(2) whether petitioner is liable for an addition to tax under section 6660.

FINDINGS OF FACT2

Some of the facts have been stipulated; the stipulation and the stipulated…

2Cases cited29 opinions

  1. United States v. CartwrightSupreme Court of the United States · 1973
  2. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  3. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  4. Mailman v. CommissionerUnited States Tax Court · 1988
  5. Reiff v. CommissionerUnited States Tax Court · 1981

24 more not listed; retrieve them via the Exa API.

3Cited by54 opinions

  1. Rosa Shackleford, Personal Representative of the Estate of Thomas J. Shackleford, Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 2001
  2. Cook v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 2003
  3. Estate of Mellinger v. CommissionerUnited States Tax Court · 1999
  4. Jameson v. CommissionerUnited States Tax Court · 1999
  5. Estate of Simplot v. Comm'rUnited States Tax Court · 1999

49 more not listed; retrieve them via the Exa API.

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