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reports prepared by Young and Dilmore, the original return
reflects the date-of-death values of decedent's interests in
parcels A and B as $3,400,000 and $897,500, respectively.
On July 28, 1988, the Circuit Court of Calhoun County
entered a Judgment of Final Settlement in the special
administration in which the court approved a final accounting of
the special administration, awarded fees to Rivers and her
attorneys for the special administration, and directed that fees
be paid to Holman and Spraggins as coexecutrices of decedent's
estate. The parties to the will contest resolved their dispute
shortly thereafter.
After the settlement of the will contest, Holman and
Spraggins hired an accounting firm to facilitate their
responsibilities as executrices of decedent's estate. In
preparing an amended estate tax return (amended return), the
accounting firm hired the Hearn Co. (Hearn) for the purpose of
conducting another appraisal of the trust property. Relying on
the Hearn appraisal, the amended return reflects the date-of-
death values of decedent's interests in parcels A and B as
$650,000 and $375,000, respectively. Holman and Spraggins filed
the amended return on October 6, 1988. Unlike the original
return, the amended return included specific amounts for each
applicable line thereon and was capable of being processed by the
IRS.
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