- 13 - On November 7, 1988, the executor timely filed Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return (estate tax return), on behalf of decedent's estate (estate). The executor reported in the return that the fair market value of decedent's interest in Marrero Land on the valuation date was $4,312,018. Respondent issued a notice of deficiency (notice) to the estate and the executor. Respondent determined in the notice that the fair market value of decedent's interest in Marrero Land on the valuation date was $13,100,000. The executor timely filed Form 843, Claim for Refund and Request for Abatement (refund claim), on behalf of the estate. The executor reported in the refund claim that the fair market value of decedent's interest in Marrero Land on the valuation date was $2,400,000, and not the value reported in the estate tax return, and that consequently the estate was entitled to a refund of Federal estate tax. OPINION The estate modified the position that it took in the refund claim as to the fair market value of decedent's interest in Marrero Land on the valuation date. The estate now claims that the fair market value of that interest on that date is between $3,486,167 and $3,933,412. In the alternative, the estate contends that the maximum fair market value of decedent's in-Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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