- 15 - 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 basedPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011