- 37 -
We accordingly hold that the fair market value of decedent’s
one-half interest in the Busch property at his date of death is
$4,190,496 ($9,312,992 x .50 = $4,656,496 - $466,000 =
$4,190,496).11
To reflect the foregoing,
Decision will be entered under
Rule 155.
10(...continued)
results in an overall discount from the $150,000 value for
decedent’s one-half interest of 38.4 percent.
11 Because we have held that the fair market value that
should have been included in decedent’s gross estate exceeds the
amount reported by the estate, it is not necessary to consider
respondent’s contention that we are without jurisdiction, in the
circumstances of this case, to decide an overpayment in estate
tax.
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Last modified: May 25, 2011