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Silverman v. Commissioner of Internal Revenue

decided: June 21, 1976.

SEYMOUR SILVERMAN, ET AL., PETITIONERS-APPELLANTS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE



Appeal from a decision of the United States Tax Court, William H. Quealy, Judge, finding petitioners liable for gift tax deficiencies for the taxable year 1968 arising from gifts of stock in closely-held corporation. Affirmed.

Hays, Mulligan and Gurfein, Circuit Judges.

Author: Hays

HAYS, Circuit Judge:

Taxpayers Seymour and Helen Silverman and Jack and Frances Silverman appeal from decisions of the United States Tax Court entered May 20, 1975, pursuant to a Memorandum Opinion and Findings of Fact by Judge William H. Quealy*fn1 filed November 6, 1974, which determined that Seymour and Helen Silverman each owed a deficiency of $43,890 in gift taxes for the year 1968 and that Jack and Frances Silverman each owed a deficiency of $94,395 in gift taxes for the same year.*fn2 The gifts for which the deficiencies were assessed consisted of shares of class B common stock of Modern Maid Food Products, Inc. ("Modern Maid") transferred to certain trusts organized by the taxpayers. We affirm.

I

Modern Maid, a New York corporation, is engaged in the business of manufacturing and selling breading and batter mixes for use by processors of shrimp, fish, and poultry, and the manufacturing and selling of prepared flour mixes to wholesale grocers. Modern Maid is the corporate successor to a partnership formed in 1933. Prior to August 12, 1968, the capitalization of Modern Maid and its equity holders' respective stock interests were as follows:

Common Stock Preferred Stock

$100 Par Value $100 Par Value

Jack Silverman 1,284 265

Seymour Silverman 645 430

Harold Oppenheim 225 150

Stanley Silverman 3 10

Joel Silverman 3 ...


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