Tracy v. Alexander

The opinion of the court was delivered by

William J. Brennan, Jr., J.

The executrix complains in this transfer inheritance tax proceeding of the bureau’s evaluation of a minority stock interest in a closely held corporation. We certified of our own motion her appeal to the Appellate Division.

The decedent died June 29, 1951. The bureau assessed 531 shares of the common stock of Nevins-Church Press, Inc., a New Jersey corporation, at $813.54 per share. Appellant contends that the value of the stock is not in excess of $600 per share, the value determined for federal estate tax purposes by the…