Estate of Suzanne W. Cullison, Deceased, J. Greg Cullison, Personal Representative - Page 8

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               As Jerry was familiar with decedent's land and knowledgeable           
          about farmland prices in the Wellton area, he helped her and Mr.            
          Shadle to value each of her four parcels.  In valuing decedent's            
          land, Jerry further considered detailed information on recent               
          sales of farmland in the area which he obtained from a title                
          company.  Jerry concluded that decedent's four parcels had a                
          total combined market value of $1,865,500.                                  
               As a result, Mr. Shadle knew that, if decedent were to avoid           
          potential Federal estate and gift tax liabilities in connection             
          with the private annuity transaction, the private annuity payable           
          to her should also have a value of $1,865,500.  He provided this            
          information to Mr. Schulte, decedent's accountant, since Mr.                
          Schulte would determine the annual payment the grandchildren                
          should make to decedent under the private annuity.                          
               On the basis of certain information contained in Table V of            
          section 1.72-9, Income Tax Regs.,1 Mr. Schulte concluded that a             
          person decedent's age of about 81 years in late 1988 would have a           

               1  Although Mr. Schulte testified he used Table V in sec.              
          1.72-5, Income Tax Regs., he apparently meant and was referring             
          to Table V in sec. 1.72-9, Income Tax Regs., as there is no Table           
          V in sec. 1.72-5, Income Tax Regs.  It is further to be noted               
          that Table V and other similar tables in sec. 1.72-9, Income Tax            
          Regs., are used in determining the exclusion ratio specified in             
          sec. 72(b).  In general, this exclusion ratio is applied for                
          Federal income tax purposes in determining the portion of an                
          annuity payment excludable from a taxpayer's gross income as a              
          nontaxable return of the taxpayer's investment in the annuity               
          contract.  See generally sec. 72(b); sec. 1.72-4(a), Income Tax             
          Regs.  Table V thus is not directly applicable to the valuation             
          of annuities for Federal estate and gift tax purposes.                      




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