Scanlan v. Commissioner

Full Text of Court Cases
July 24, 1996
4813 Telephone Communications, Except Radiotelephone
517311 Wired Telecommunications Carriers
estate and gift taxation
valuation date, marketability

Scanlan v. Commissioner
T.C. Memo 1996-331, 72 T.C.M. (CCH) 161
Federal Court
United States Tax Court
David Blackshear Hamilton Chaffe III (for petitioner)


At issue is the value of decedent's stock in Eatelcorp, Inc. on the date of his death and the date of a gift that was made approximately 3 months beforehand.

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Thorough Update of Reports Essential

The Tax Court valued an undivided 50% interest in a closely held telecommunications company as of the 1991 valuation date. The court rejected the IRS' argument that a 1994 redemption of all non-Scanlan family stock was indicative of the 1991 fair market.