Estate of Frank A. Branson - Page 13




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          decedent's widow during her life, and upon her death, the                   
          remainder to be distributed to March; (2) 1,000 shares of Savings           
          stock in trust for each of decedent's four grandchildren; and               
          (3) the remaining 4,889 shares of Savings stock and 500 shares of           
          Willits stock to March as part of the residue of the estate.  The           
          will provided that all estate taxes were to be paid from the                
          residue of the estate.                                                      
               Pursuant to a court order, March was granted authority to              
          sell 2,800 shares of Savings stock at $335 per share and 500                
          shares of Willits stock at $850 per share.  March sold the shares           
          and paid Federal and State of California estate taxes of                    
          $1,008,698 and $200,632, respectively.  March, as executrix and             
          residuary legatee, assumed individual liability for any estate              
          taxes later found due from petitioner.                                      
               Petitioner reported the value of the Savings and Willits               
          shares as $181.50 and $485, respectively, per share, on its Form            
          706, United States Estate (and Generation-Skipping Transfer) Tax            
          Return.  Petitioner reported the capital gain from the sales of             
          the Savings and Willits shares on Schedule D of its 1992 Form               
          1041, U.S. Fiduciary Income Tax Return, which it filed on or                
          about April 15, 1993.  Petitioner calculated the gain by                    
          subtracting the value of the shares reported on the estate tax              
          return from the amount received from their sale.  Petitioner                
          reported $429,800 of gain from the sale of the Savings shares and           





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