Estate of Marmaduke v. Commissioner of Internal Revenue

BVLaw
Full Text of Court Cases
October 14, 1999
5942 Book Stores
451211 Book Stores
estate and gift taxation
estate tax, fair market value (FMV), employee stock ownership plan (ESOP)

Estate of Marmaduke v. Commissioner of Internal Revenue
T.C. Memo 1999-342,1999 Tax Ct. Memo LEXIS 397
US
Federal Court
United States Tax Court
Robert F. Reilly (for estate)<br>Z. Christopher Mercer (for estate)<br>Travis Keath (for IRS)
Swift

Summary

At issue is the fair market value, as of the date of decedent's death, of 366,385 shares of common stock of a closely held corporation.

See Also

Tax Court Holds Sales Transactions Not Indicative of FMV

This issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc.

Small-Block Sales Not Indicative of FMV; 30% Marketability Discount Applied

The issue in this estate tax matter was the fair market value on Sept. 7, 1993, of decedent's 366,385 shares of common stock of Hastings Books, Music & Video Inc., a closely held corporation.

Illiquidity Increases With Block Size

The Tax Court determined the fair market value, including a discount for lack of marketability, of a large block of stock in a retail books, music, and video chain operating in the South and Southwest.