- 17 - an expectancy interest in Mr. DiSanto’s estate because (a) no shares had been transferred while she was alive,(b) Mr. DiSanto’s estate could have sold some of those shares to pay administration expenses, and (c) Mr. DiSanto gave her a residuary interest, not stock. We disagree. There is no evidence that Mr. DiSanto’s estate needed to sell MD&F stock to pay administration expenses. 2. Value of MD&F Stock That Mrs. DiSanto Was Entitled To Receive Under Mr. DiSanto’s Will After Her 1993 Disclaimer We next decide whether to accept the values for MD&F stock that Mrs. DiSanto was entitled to receive (which are lower than those estimated for petitioners by Deloitte & Touche, MPI, and Frazier) as contended by petitioners, or higher values, as contended by respondent. Petitioners contend that the Deloitte & Touche estimates are unreliable because Braly was inexperienced and made errors in Mrs. DiSanto’s estate tax return. We disagree. Braly relied on Deloitte & Touche valuation experts to estimate the values of assets to use in Mrs. DiSanto’s estate tax return. Petitioners contend that Mrs. DiSanto’s estate overestimated the value of her interest in Mr. DiSanto’s estate. We disagree. There is no evidence that Deloitte & Touche made errors in appraising Mrs. DiSanto’s estate. Deloitte & Touche’s and MPI’s estimates are similar. MPI used the same general principles to appraise the value of Mrs. DiSanto's interest in her husband's estate that it usedPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011