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ESTATE OF DAVIS v. COMMISSIONER

Docket No. 9337-96.

110 T.C. 530 (1998)

ESTATE OF ARTEMUS D. DAVIS, DECEASED, ROBERT D. DAVIS, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 30, 1998.

Attorney(s) appearing for the Case

Gregory V. Nelson, John W. Porter, and Richard A. Husseini, for petitioner.

Victoria J. Sherlock, Norman N. Pickett, and Harve M. Lewis, for respondent.

CHIECHI, Judge:

Respondent determined a deficiency of $5,283,894 in the Federal gift tax of Artemus D. Davis (decedent) who died on June 11, 1995, after he made the two gifts to which that deficiency pertains. The sole issue for decision is the fair market value on November 2, 1992, of each of two blocks of 25 shares of common stock of A.D.D. Investment & Cattle Co. (ADDI&C), one of which decedent gave to his son Robert D. Davis (Robert Davis) and the...

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