Estate of Juanita F. Sirmans, Deceased Dan L. Sirmans, Executor - Page 15

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             slightly from the amount discussed in petitioner's post-                 
             trial briefs, $509,259.                                                  
                  In the subject notice of deficiency, among other                    
             adjustments, respondent determined that the value of the                 
             subject property on the date of the decedent's death was                 
             $791,000.  The notice includes the following explanation                 
             of the adjustment:                                                       

                  The fair market value, at the date of                               
                  decedent's death, of the 56.5 acres located in                      
                  the northwest 1/4 of the south 1/22 of section                      
                  2, Township 28 South, Range 19 East, Tampa,                         
                  Hillsborough County, Florida, was $791,000.00                       
                  instead of $509,529.00 as reported on the estate                    
                  tax return.  Accordingly, the reported value of                     
                  the taxable estate is increased $281,471.00.                        

                                       OPINION                                        
                  The sole issue for decision in this case is whether                 
             the 56.5 acres owned by the decedent on the date of her                  
             death was worth $791,000, as determined by respondent, or                
             $509,529, as reported on the estate tax return filed on                  
             behalf of the decedent's estate.  Petitioner bears the                   
             burden of proving the fair market value of the 56.5 acres                
             owned by the decedent on the date of her death.  Rule                    
             142(a).  All Rule references are to the Tax Court Rules of               
             Practice and Procedure.                                                  
                  The value of the subject property as determined by                  
             respondent in the notice of deficiency, $791,000, is based               




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