- 6 - Petitioner timely filed Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return (original return), on May 19, 1993. On Schedule A, Real Estate, attached thereto, petitioner valued Cane Mill at $2,882,000, its fair market value (FMV) as determined by its appraiser, Eley C. Frazer III (Frazer). Petitioner made a valid protective election for special use valuation under section 2032A with respect to Cane Mill on the Schedule A-1, Section 2032A Valuation, attached to the original return. Petitioner also made a "qualified woodlands" election pursuant to section 2032A(e)(13) with respect to 2,929.1 acres of timberland located on Cane Mill. In addition, petitioner claimed a deduction for interest on the Note in the amount of $49,589 on Schedule J, Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims, attached to the original return. Petitioner also claimed a deduction in the amount of $545,536 for alimony due decedent's former wife under the terms of their divorce on Schedule K, Debts of the Decedent, and Mortgages and Liens, attached to the original return. By letter dated January 10, 1996, respondent's estate tax attorney, Travis Vance III, advised petitioner that respondent proposed to make certain adjustments to decedent's taxable estate, none of which were related to the FMV of Cane Mill as reported on the original return. On March 8, 1996, petitioner timely filed an amended Form 706 (amended return) in an effort toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011