Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, F.K.A. Ameritrust Company, Trustee - Page 19

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            tax return.8  Petitioners do not include in this amount the                                 
            $333,595 of income from Trust B assets, such as interest and                                
            dividends.  Thus, added to the $220,823, Trust B had a liquid                               
            reserve of $554,418 by the end of 1992.                                                     
                  Petitioners contend that Trust B needed a reserve for taxes                           
            of at least $749,696, the total of the deficiencies determined in                           
            the notices of deficiency.  We disagree.  The deficiency arose                              
            because respondent determined that the value of Ripplestone was                             
            more than reported by petitioners.  However, when they received                             
            the notices of deficiency, petitioners knew that Ripplestone was                            
            worth less than its reported value because of ground                                        
            contamination and zoning problems.                                                          
                  Apparently, when the estate filed the return, the executor                            
            did not know of those problems or that the fair market value of                             
            Ripplestone was less than the value reported on the estate tax                              
            return.  Petitioners will receive a refund from respondent due to                           
            the reduced fair market value of Ripplestone regardless of our                              
            decision here.                                                                              



                  8 Petitioners computed this amount by subtracting $362,106                            
            (alleged by petitioners to be additional Ohio estate tax payable)                           
            and $291,363 (administration expenses deducted on the return but                            
            not yet paid) from $874,292, which was the fair market value of                             
            Trust B's cash and cash equivalents on June 29, 1990.  There is                             
            no evidence of the value of Trust B's cash and cash equivalents                             
            on Mar. 16, 1990, when the estate filed the estate tax return.                              





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