Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 18

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          as of my date of death.”  In filing the return for John's estate            
          in her capacity as executrix thereof, decedent did not obtain an            
          independent appraisal of the Johnco stock passing through the               
          estate.  According to petitioner, since the $86.80 per-share                
          value reported on the return was not the product of an                      
          independent appraisal, the terms of John's will preclude its use            
          in determining the number of shares required to satisfy the                 
          unified credit bequest to Andrew.  Instead, petitioner contends,            
          the number of shares passing to Andrew must be determined on the            
          basis of the December 1992 appraisal performed by RPR of the                
          value of the Johnco shares as of John's date of death; namely,              
          $44.65 per share.  This appraisal was independent, having been              
          commissioned by Northern Trust in its capacity as successor                 
          independent administrator of John's estate in order to comply               
          with the terms of John's will in funding the unified credit                 
          bequest to Andrew.                                                          
               The upshot of petitioner's position is that John's estate              
          may report one value for the Johnco stock on the estate tax                 
          return while another, lower value for the stock may be used for             
          purposes of funding a unified credit bequest made in John’s will.           
          For the reasons outlined below, we disagree and instead conclude            
          that the valuation used on John's estate's return must also be              
          used for purposes of funding the unified credit bequest.                    
               Although the determination of the number of Johnco shares              
          that passed to Andrew pursuant to the unified credit bequest and            
          to decedent under the residuary clause of John's will turns upon            


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