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Decedent's Federal estate tax return was due to be filed on
November 20, 1987. Rivers, however, requested and received an
extension of time to file that return. An additional extension
was requested and received, extending the due date of the return
to November 20, 1988. On June 16, 1988, an order was issued by
the Circuit Court of Calhoun County authorizing Rivers to file
the Federal estate tax return. On June 22, 1988, consistent with
that order, Rivers filed the Federal estate tax return (original
return). The original return, however, was not in a form capable
of being processed by the Internal Revenue Service (IRS). It
contained the word "unknown" on essentially every line of the
return. Only line 1, involving the total gross estate, and lines
9 and 11, involving the unified credit, contained values of any
significance. The total gross estate, as listed on the original
return, equaled $10,902,474.64.
In computing the total gross estate, it was necessary for
Rivers to value two parcels of real estate (trust property) held
in trust (trust) in which decedent possessed an undivided one-
half interest on the date of his death (valuation date). The
first parcel (parcel A) contains approximately 65 acres of land,
and the second parcel (parcel B) consists of approximately 10
acres of land. Through her attorney, William Henry Agee (Agee),
Rivers retained the services of T.E. Young (Young) and Gene
Dilmore (Dilmore), two unaffiliated professional appraisers, for
the purpose of valuing both parcels. Relying on the appraisal
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