Very interesting question. I could see an argument that you sold the
stock at closing for $35 dollars per share and that the remaining
$4/share over the $31/share you receive immediately could be eaten
partially in transaction costs, but for 8282 purposes the transaction
was complete at closing. On the other hand, I can see an argument to
you started the sale at closing that wasn't complete until 2 years
Probably worth a call to your attorney.
Director of Development
Savannah Country Day School
824 Stillwood Drive
Savannah, GA 31419
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>>> Shannon Schulz <[log in to unmask]> 2/14/2008 9:55 am >>>
We were given 25,000 shares of a privately held company in December.
January, the company was purchased by a large company. We are expected
receive approximately $35/share...$31/share within a month of the
(slated to happen in March '08) with any residual amount left (after
existing liabilities, taxes, etc.) within 2 years. We're very glad to
a sizable gift of private stock liquidate so quickly.
It seems appropriate that we wait until the entire transaction is
(approx 2 years) before filing 8282. Does this seem correct?
For valuation purposes, because the sale happened so close to the gift
is a separate appraisal needed or does the sale price substantiate the
therefore the donor's deduction and our amount to record?
Thank you for any input.