Estate of Suzanne W. Cullison, Deceased, J. Greg Cullison, Personal Representative - Page 23

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          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 10           





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