- 4 - discount to reflect the corporations' built-in capital gains tax liability. In determining the value of decedent's shares of ESI and ISC on the estate tax return, the estate combined the Mercer valuation of the corporations' value with estimates of the value of the real property owned by both corporations, and then applied a 34-percent discount for built-in capital gains on the real property and a 50-percent discount for decedent's minority interest.3 The estate's computation is as follows: ESI ISC Mercer value $670,000 $1,809,000 Real estate value 750,000 500,000 total value 1,420,000 2,309,000 Less: discount for capital gains on real estate (34%) 255,000 170,000 Less: 50% discount for minority interest 582,500 1,069,500 discounted value 582,500 1,069,500 Number of shares outstanding 570 836 Per share value 1,020.84 1,276.02 Number of shares owned 3 As for the capital gains discount, the estate did not deduct the adjusted basis of the properties owned by ESI or ISC. The capital gain rate of 34 percent was applied to the estimated real estate values of the respective properties. The parties agree that the estate should have deducted the adjusted basis from the estimated real estate values. Our holding makes this computational adjustment unnecessary.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011