- 4 - On September 22, 1991, Decedent died leaving her 20-percent interest in the Partnership in trust. In connection therewith, her will stated: My said executrix and trustee is hereby given full authority and power * * * to continue and carry on any business in which I am engaged at the time of my death, including the continuation of any partnership in which I may be interested at the time of my death, particularly the partnership with my said brother, J.S. Meldrim, and that to facilitate the uninterrupted continuance of said partnership operation, my said executrix and trustee is hereby designated a substituted partner in said partnership, if deemed desirable by said executrix and trustee, for and during the administration of my estate and said trust; * * * When Decedent died, the Partnership owned 5,501 acres of land and timber in St. John's County, Florida, along with other assets. On petitioner's Form 706, United States Estate Tax Return, Personal Representative reported that the fair market value of Decedent's 20-percent interest in the partnership equaled $533,895. Upon audit, respondent determined that the fair market value was $1,147,177. Respondent valued the 20-percent interest by: (1) Valuing the Partnership's land and timber by reference to comparable sales, (2) adding 20 percent of this value to 20 percent of the fair market value of the other assets of the partnership as reported on Form 706, (3) applying a 10-percent discount to take into account Decedent's fractional interest in the Partnership, and (4) applying a 15-percent discount to reflect other factors such as the lack of marketability.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011