Estate of Lewis A. Bailey, Deceased, Frances Jeanette Foster, Executrix - Page 7




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          original Biles report), prepared by Ralph W. Biles, an Arkansas             
          State certified general appraiser, appraising the fair market               
          value of the Arkansas motel to be $2,380,000; and (2) a March               
          1996 report (the Ohrmund report), prepared by Ronald D. Ohrmund,            
          a California certified general appraiser, appraising the fair               
          market value of the California motel to be $1,388,000.                      
               When the estate tax return was filed, the executor of                  
          decedent’s estate was unaware of decedent’s individual one-half             
          ownership interest in parcel 2.  Consequently, this asset was not           
          separately reported on the estate tax return.  Similarly,                   
          decedent’s one-half ownership interest in parcel 2 was not taken            
          into consideration in the Ohrmund report’s valuation of the                 
          California motel or otherwise reflected in the valuation of                 
          decedent’s C&L Bailey shares as reported on Form 706.                       
               The Promissory Note                                                    
               On decedent’s estate tax return, the $148,700 promissory               
          note was listed on Schedule E–-Jointly Owned Property, as                   
          decedent’s and Melba’s joint property; consequently, a one-half             
          interest in the promissory note ($74,350) was reported as being             
          included in decedent’s gross estate.                                        
          Notice of Deficiency                                                        
               On or about June 13, 1997, respondent commenced the                    
          examination of decedent’s estate tax return.  On July 2, 1999,              
          respondent issued the notice of deficiency.                                 






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