- 23 - 10, 1994, executors or donors can rely on Notice 89-24, supra, or Notice 89-60, supra, in valuing the transferred interest. Sec. 20.7520-4, Estate Tax Regs.; sec. 25.7520-4, Gift Tax Regs. Thus, contrary to petitioner's argument, the valuation methodology respondent employed is specifically required by the transitional rules provided in section 25.7520-4, Gift Tax Regs. Applying Notice 89-24, supra, and Notice 89-60, supra, respondent, in the notice of deficiency dated March 13, 1996, determined that the private annuity decedent received had a value of $1,360,724. In addition, the record discloses that decedent's accountant did not reasonably value the annuity decedent was to receive. The accountant did not follow the procedure specified in Notice 89-24, supra, and Notice 89-60, supra, as he testified that he had been unaware of the enactment of section 7520. Moreover, he did not even value the annuity pursuant to the actuarial table prescribed under the estate and gift tax regulations in effect in late 1988, which were issued in 1984. See supra note 5. He used an interest rate of 9 percent (which he believed was a rate slightly higher than the then prevailing interest rate charged on land sales contracts in Arizona), notwithstanding that the actuarial tables contained in the estate and gift tax regulations then in effect (in late 1988 when decedent's accountant apparently valued the annuity) used an interest rate factor of 10Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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