Court Accepts Taxpayer's Expert Value Despite Taxpayer Protests
The issues in this estate tax matter were as follows: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on his date of death; and the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on his date of death.
Petitioners' expert accepted despite their claim of lower value
The Experts: Clifford Braly III (for taxpayers on returns) Deloitte & Touche Management Planning, Inc. (for petitioners at trial) William H. Frazier, ASA (for petitioners ...
Estate of DiSanto v. Commissioner
At issue is the fair market value of a block of 186,177 shares of MD&F stock owned by the decendent.
Petitioners' Expert Accepted Despite Their Claim of Lower Value: Marital Deduction Based on Stock Actually Inherited After Disclaimer
The issues in the estate tax matter were: the fair market value of Frank DiSanto's (Frank) 186,177 shares (53.5%) of stock in Morganton Dyeing & Finishing Corp. (MD&F) on the date of death; the fair market value of the MD&F stock Grace DiSanto (Grace) was entitled to inherit from Frank's estate (a minority interest) on her date of death; whether Grace had expectancy interest only in the stock she was entitled to inherit; and whether Frank's estate was entitled to a marital deduction based on the value of the stock he willed to Grace or based on the value of the stock she was entitled to receive after executing a disclaimer of part of her interest in the stock.
A Post-Valuation Date Redemption and a Marital Deduction
The Tax Court determined that the fair market value of stock in a fabric dying corporation.