Estate of Littick v. Commissioner
United States Tax Court
Three brothers, one of whom was facing death from cancer, owned almost equal stock control of a corporation. In order to insure continuity of ownership in the family, they and the corporation agreed that upon the death of any, the corporation would buy the deceased brother's interest for $ 200,000. This was done and the stock of decedent was valued in the estate tax return at $ 200,000. The Commissioner determined that the stock should have been valued at $ 257,910.97, its…
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Three brothers, one of whom was facing death from cancer, owned almost equal stock control of a corporation. In order to insure continuity of ownership in the family, they and the corporation agreed that upon the death of any, the corporation would buy the deceased brother's interest for $ 200,000. This was done and the stock of decedent was valued in the estate tax return at $ 200,000. The Commissioner determined that the stock should have been valued at $ 257,910.97, its fair market value. Held, on the facts, the stock was burdened with terms of the agreement and was properly returned at a…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined a deficiency in estate tax of $25,286.22.
The question for decision is whether 670 shares of common stock in the Zanesville Publishing Company owned by decedent at the time of his death subject to the terms of a certain contract between decedent and other stockholders should be valued for estate tax purposes at $200,000 as reported by the estate or at its fair market value $257,910.57 as determined by the Commissioner.
FINDINGS OF FACT.
Part of the facts are stipulated, are so found, and the stipulation and the pertinent exhibits are included herein by…
2Cases cited7 opinions
- Wilson v. BowersCourt of Appeals for the Second Circuit · 1932
- Lomb v. SugdenCourt of Appeals for the Second Circuit · 1936
- Brodrick v. GoreCourt of Appeals for the Tenth Circuit · 1955
- Estate of Salt v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. BenselCourt of Appeals for the Third Circuit · 1938
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Estate of Hall v. CommissionerUnited States Tax Court · 1989
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Estate of Bischoff v. CommissionerUnited States Tax Court · 1977
- Citizens Bank & Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Estate of True v. CommissionerCourt of Appeals for the Tenth Circuit · 2004
23 more not listed; retrieve them via the Exa API.