- 9 -
stock that were not apportioned to Andrew under Article VI of
John's will. Thus, at the time of her death, decedent's interest
in Johnco stock consisted of the 82,865 shares held by John at
his death, less however many shares were required to fund
Andrew's share of the unified credit bequest.
Decedent was named the initial executrix of John's estate
and served in that capacity until her death. As executrix,
decedent timely filed an estate tax return Form 706, Estate (and
Generation Skipping Transfer) Tax Return, for John's estate,
reporting a value of $7,192,967 ($86.80 per share) for the Johnco
stock passing through his estate. At the time of her death,
decedent had not yet funded the unified credit bequest to Andrew
and had not obtained an independent appraisal of the Johnco
stock.
B. Number of Shares and Value Reported on Decedent's
Form 706
Following decedent’s death, in addition to serving as
independent executor of the Estate, Northern Trust was appointed
successor independent administrator of John’s estate. In
December 1992, at the request of Northern Trust, Clyde Buck of
Rauscher Pierce Refsnes, Inc. (RPR), a Dallas, Texas, investment
banking firm, performed two appraisals of Johnco stock: (1) The
value of decedent's Johnco stock on her date of death (Decedent
Appraisal); and (2) the value of the Johnco stock held by John on
his date of death (John Appraisal). The record in this case
contains the Decedent Appraisal but not the John Appraisal. The
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