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Sec. Form 706
2040 Form 706 Fractional
Value of Percent Value Interest
Fee Included Before Discount Form 706
Simple Per Form FractionalPercentageReturned
No. Description Interest 706 Discount Claimed Value
1 Checking Acct. #1 $26,24450.00 $13,122 -- $13,122
2 Savings Acct. 5,214 50.00 2,607 -- 2,607
3 Checking Acct. #23,480 50.00 1,740 -- 1,740
4 CD 100,000 50.00 50,000 -- 50,000
5 Laidley 275,000 100.00 275,000 15 233,750
6 Valencia 965,000 78.87 761,096 15 646,932
7 South Fitch 29,000 78.39 22,733 15 19,323
8 Chenery 250,000 53.68 134,200 15 114,070
9 Dolores 435,000 53.67 233,465 15 198,444
10 Onondaga 400,000 55.32 221,280 15 188,088
11 Acadia 90,000 100.00 90,000 35 58,500
In the notice of deficiency, respondent determined that
decedent's estate was not entitled to claim any credit pursuant
to section 2040 or fractional interest discounts in any amount on
the parcels of real property described as items 5 through 11 on
Schedule E of Form 706.
On Form 706, Schedule K, Debts of the Decedent, and
Mortgages and Liens, decedent's estate claimed deductions for,
among other things, a portion of the mortgages related to the
Dolores and Onondaga properties. On Schedule K, decedent's
estate allocated the mortgages on the properties in amounts equal
to the section 2040 inclusion percentages for the respective
pieces of property. The following table contains amounts related
to the deductions for mortgages on the Dolores and Onondaga
properties, which amounts were reported on Schedule K:
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