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with a revised offer. I believe we are in basic
agreement on the settlement, but we will request
our appraiser to review the proposal. I wish to
thank you for the information provided. Please
keep me up to date on the title transfer. If
you need any further information, feel free to
contact me.
Several months later, Mr. Caruthers sent another
letter dated October 3, 1991, to Mr. Sirmans:
I have enclosed for your handling a Purchase
Agreement in the amount of $100,795.27 for the
acquisition of the above referenced Parcel 123.
Thus, the purchase price for decedent's 4.83 acres,
$100,795.27, was based upon an agreed price paid for the
land of $20,000 per acre. The purchase price was reduced
by a property tax arrearage in the amount of $29,611.42,
and airborne and wiring charges totaling $40. Accordingly,
the estate ultimately received cash in the amount of
$71,143.85 for the 4.83 acres.
Mr. Sirmans filed Form 706, United States Estate (and
Generation Skipping Transfer) Tax Return, as executor of
the decedent's estate. He did not elect alternative
valuation. Thus, he reported the value of the decedent's
assets as of the date of death. On Schedule A--Real
Estate, attached to the estate tax return, Mr. Sirmans
reported $509,529 as the value of the subject 56.5 acres.
In computing that amount, Mr. Sirmans concluded that the
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