Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, F.K.A. Ameritrust Company, Trustee - Page 8

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                  Alexander and the trustee decided to sell Ripplestone as                              
            soon as possible after decedent's personal property in                                      
            Ripplestone was distributed.  Decedent's estate paid expenses to                            
            maintain and preserve decedent's personal property and                                      
            Ripplestone.  The Cleveland Museum of Art selected the items it                             
            wanted, and the estate sold the remaining personal property in                              
            February or March 1990.                                                                     
            F.    Appraisals and The Estate Tax Return                                                  
                  Shortly after decedent died, the trustee of Trust B                                   
            commissioned an appraisal to estimate the fair market value of                              
            Ripplestone as of July 19, 1989.  On July 28, 1989, Ripplestone                             
            was appraised at $3.7 million as of July 19, 1989.  The appraiser                           
            assumed that Ripplestone could be subdivided and that Ripplestone                           
            was free of materials that would present an environmental risk.                             
            Those assumptions were incorrect.                                                           
                  The estate filed its Federal estate tax return on March 16,                           
            1990, and paid Federal and State taxes.  Decedent's estate                                  
            reported on its Federal estate tax return that the value of                                 
            Ripplestone was $3.2 million.  Decedent's estate deducted                                   
            $213,541.82 for maintenance and upkeep of Ripplestone and                                   
            $150,000 for costs it estimated it would incur to sell                                      
            Ripplestone.  Ripplestone was listed for sale on March 20, 1990,                            
            for $4,200,000.                                                                             







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