Estate of Foote v. Commissioner of Internal Revenue

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February 5, 1999

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3492 Fluid Power Valves and Hose Fittings
332912 Fluid Power Valve and Hose Fitting Manufacturing
estate and gift taxation
Estate of Foote v. Commissioner of Internal Revenue
T.C. Memo 1999-37,1999 Tax Ct. Memo LEXIS 37
US
Federal Court
United States Tax Court
Robert E. Kleeman, Jr., CPA (for estate), Robert L. Davis, CFA (for IRS)
Jacobs

Summary

At issue is the fair market value of 280,507 shares of Applied Power, Inc. class A common stock held by the decedent.

See Also

Relevant Factors Make Expert's Conclusion More Reliable

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The issue in this estate tax matter is the appropriate blockage discount, if any, to apply in valuing decedent's shares of Applied Power stock.

Consideration of All Relevant Factors Makes Expert's Conclusion More Reliable

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The issue in this estate tax matter is the appropriate blockage discount, if any, to apply in valuing decedent's shares of Applied Power stock.

Small Blockage Discount Supported by Post-Valuation Date Sales

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The Tax Court permitted a blockage discount of 3.3% on the decedent's 2.2% interest in a NYSE stock.