Legal Opinion
Estate of Artemus D. Davis, Robert D. Davis, Personal Representative v. Commissioner
United States Tax Court
Decided June 30, 1998No. Docket 9337-96Unknown
1Opinion of the Court
Chiechi, Judge:
Respondent determined a deficiency of $5,283,894 in the Federal gift tax of Artemus D. Davis (decedent) who died on June 11, 1995, after he made the two gifts to which that deficiency pertains. The sole issue for decision is the fair market value on November 2, 1992, of each of two blocks of 25 shares of common stock of A.D.D. Investment & Cattle Co. (addi&c), one of which decedent gave to his son Robert D. Davis (Robert Davis) and the other of which decedent gave to his son Lee W. Davis (Lee Davis).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Decedent…
2Cases cited33 opinions
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Parker v. CommissionerUnited States Tax Court · 1986
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