Estate of Ruth J. Casey, Deceased, First Interstate Bank of Nevada, Special Administrator - Page 5

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          were about $800,000, which resulted in a $100,000 cash                      
          distribution to decedent’s living trust during December 1989.               
               All testing of the realty had been completed during the                
          spring of 1990; thereafter, the trustee set a $24 million asking            
          price for Residence.  Decedent, throughout the entire time and              
          until the date of her death on May 2, 1990, resided in Residence.           
          The trustee received a $17,500,000 cash offer on June 8, 1990,              
          from a former Apple Computer executive, which was accepted on               
          June 11, 1990.  The sale closed on June 29, 1990.  Decedent’s               
          living trust received a $6,300,000 distribution during August               
          1990.                                                                       
               After the real estate closing, a dispute arose over the fee            
          of the trustee of the Liquidating Trust.  During September 1991,            
          decedent’s living trust received a $1,500,000 distribution from             
          the Liquidating Trust.  After the settlement of the litigation              
          concerning the trustee’s fee, an additional $190,000 was received           
          by decedent’s living trust.  The parties agree that the                     
          Liquidating Trust’s net value (without any discount) at the time            
          of decedent’s death was $16,779,630.                                        
               The original estate tax return, filed August 2, 1991,                  
          reported a $6,948,806 value for decedent’s interest in the                  
          Liquidating Trust (including a 15-percent discount).  Following             
          respondent’s issuance of the notice of deficiency, petitioner               
          filed a refund claim using a 25-percent discount for                        
          marketability.  Petitioner, at trial and on brief, seeks a 50-              




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