- 19 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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