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is the corporate trustee of the Marital Trust. As of March 31,
1992, the property held in the Marital Trust had a current market
value of $1,982,120.40, 75.13637 percent of which equals
$1,489,293.31. This is the amount of respondent's adjustment for
QTIP in the notice of deficiency.
On August 15, 1995, a payment of $441,214.40 was made by the
trustees of the Marital Trust to respondent in partial payment of
the deficiency at issue in this case.
Prior to her death, decedent was determined to be
incompetent, and a guardianship was established, with Integra
National Bank (Integra) as the guardian of her assets. Integra
prepared an estate valuation schedule listing the assets held by
the Anna Soberdash Guardianship and their values as of the date
of decedent's death. According to the estate valuation schedule
prepared by Integra, decedent owned as of the date of her death
two parcels of real estate, 1,026 shares of BT Financial Corp.
common stock, and household goods, all of which were reported on
the Federal estate tax return. The remaining assets listed on
the estate valuation schedule prepared by Integra were cash
equivalents. These were not reported separately on decedent's
Federal estate tax return. Rather, an aggregated amount of
$368,050.76 was reported as "cash".
As of the date of decedent's death, she owned the following
cash equivalents listed on the estate valuation schedule prepared
by Integra, which had the following values as of that date:
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