- 7 - perfect its protective election for special use valuation. On Schedule A-1, petitioner claimed a special use value for the qualified woodlands in the amount of $375,711 (compared to the woodlands' reported FMV of $2,028,730). The remainder of the Cane Mill property was reported at its FMV of $853,270. On the Schedule A attached to the amended return, petitioner reported a total value of $2,132,000 for the Cane Mill property. This amount represents the FMV of Cane Mill as reported on the original return, $2,882,000, less $750,000, the maximum allowable reduction for special use valuation under section 2032A. See sec. 2032A(a)(2). Furthermore, on Schedule J of the amended return, petitioner increased the amount of its section 2053(a)(2) interest expense deduction with respect to funds borrowed from the Trust to a total of $265,754. In connection with these amendments, petitioner claimed a refund for an overpayment of estate tax in the amount of $369,248 on line 28 of the amended return. Respondent issued a statutory notice of deficiency to petitioner on April 23, 1996. Among other adjustments to decedent's gross estate, respondent disallowed the interest expense deduction in its entirety. Respondent further disallowed the deduction for alimony paid to decedent's former spouse to the extent it exceeded $400,000. (Petitioner has conceded that the proper amount of the alimony deduction is $400,000.) RespondentPage: 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