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and all Rule references are to the Tax Court Rules of Practice
and Procedure.
After concessions, we must decide the fair market value of
decedent’s interest in five partnerships as of November 11, 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, the
supplemental stipulation of facts, and the attached exhibits.
Decedent was a resident of Charlotte, North Carolina, when
he died testate on May 11, 1990. Lisa G. Gilstrap, Gregory
Godley, and Kimberly E. Godley, all of whom are grandchildren of
decedent, were appointed coexecutors of the Estate of Fred O.
Godley (estate). At the time of filing of the petition in this
case, the address of the coexecutors was in Charlotte, North
Carolina. After the filing of the petition, the original
coexecutors of the estate resigned, and Fred D. Godley (Fred
Jr.), one of decedent’s sons, succeeded as administrator c.t.a.
of the estate. A Federal estate tax return was timely filed,
under extension, on or about August 14, 1991. The estate elected
to use the alternate valuation date of November 11, 1990.
At the time of his death, decedent owned a 50-percent
interest in each of the five general partnerships in issue, with
the remaining 50-percent interest in each owned by Fred Jr. Four
of these partnerships, which were formed in 1978, owned and
operated housing projects for elderly tenants known as: Monroe
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