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The trustee of Trust B commissioned an appraisal to estimate
the fair market value of Ripplestone as of November 22, 1991. On
December 9, 1991, Ripplestone was appraised at $3 million as of
November 22, 1991. Like the earlier appraisal, the appraiser
incorrectly assumed that Ripplestone could be subdivided and that
Ripplestone was free of materials that would present an
environmental risk.
As of the date of trial, it had cost $170,084 to remove the
six underground fuel storage tanks from Ripplestone and to
remediate the contaminated area. Trust B gave funds to the
estate to pay most of the expenses to maintain and sell
Ripplestone. Decedent's estate reported on its estate tax return
that the assets of Trust B were included in the estate.
Ripplestone was sold for $2,301,750 on April 20, 1994. Selling
expenses were $142,079.70.
G. Trust B Receipts, Disbursements, and Distributions
1. Taxes Paid
On March 16, 1990, Trust B paid generation skipping tax of
$1,379,745.66 and Federal estate tax of $3,892,355.31. On that
day, Trust B paid $679,549.92, and the estate paid $9,689.81 for
Ohio estate tax pursuant to section 5731.02, Ohio Rev. Code Ann.
(Anderson 1996). On September 8, 1995, Trust B paid an
additional $223,019.00 for Ohio estate tax. Trust B and the
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