ESTATE OF DAVIS v. COMMISSIONER
United States Tax Court
HELD: In determining the fair market value on a valuation date after the repeal of the doctrine established in General Utils. & Operating Co. v. Helvering, 296 U.S. 200, 80 L. Ed. 154, 56 S. Ct. 185 (1935), of each of two minority blocks of common stock of company A, the Court is not precluded on the record presented from giving consideration to A's built-in capital gains tax as of that date of about $ 26.7 million.
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HELD: In determining the fair market value on a valuation date after the repeal of the doctrine established in General Utils. & Operating Co. v. Helvering, 296 U.S. 200, 80 L. Ed. 154, 56 S. Ct. 185 (1935), of each of two minority blocks of common stock of company A, the Court is not precluded on the record presented from giving consideration to A's built-in capital gains tax as of that date of about $ 26.7 million. HELD, FURTHER, the fair market value on the valuation date of each block of stock at issue is $ 10,338,725, determined by first ascertaining A's net asset value on that date…
1Opinion of the Court
ESTATE OF ARTEMUS D. DAVIS, DECEASED, ROBERT D. DAVIS, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ESTATE OF DAVIS v. COMMISSIONER
Tax Ct. Dkt. No. 9337-96
United States Tax Court
110 T.C. 530; 1998 U.S. Tax Ct. LEXIS 35; 110 T.C. No. 35;
June 30, 1998, Filed
Decision will be entered under Rule 155.
HELD: In determining the fair market value on a valuation date after the repeal of the doctrine established in General Utils. & Operating Co. v. Helvering, 296 U.S. 200, 80 L. Ed. 154, 56 S. Ct. 185 (1935), of each of two minority blocks of common stock of company…
2Cases cited34 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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