Estate of Lewis S. Thompson, III, Deceased, Synovus Trust Company, Successor Executor To Security Bank and Trust Company - Page 6

                                        - 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 to           




Page:  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