Estate of Fred O. Godley, Deceased, Fred D. Godley, Administrator CTA - Page 37




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          as to the valuations of those entities for Federal estate tax                 
          purposes, which valuations the parties have stipulated are                    
          correct.  Accordingly, we conclude that the accounts receivable               
          of the housing partnerships should be valued at face value, and               
          we make no adjustment to Beck’s report in this respect.13                     
               (b)  Trust Fund Accounts                                                 
               Beck assigned no value to the trust funds established and                
          maintained under the financing arrangements of the housing                    
          partnerships, on the grounds that maintenance of the funds was                
          essentially a prerequisite for the HUD subsidies and therefore                
          the funds were not available to a purchaser of decedent’s                     
          interest.  It is respondent’s contention that the trust funds are             
          includable in the net asset value of the partnerships at their                
          full face value as of December 31, 1989.  Although we disagree                
          with respondent’s approach, we also do not believe that Beck has              
          fully accounted for the value supplied by the trust funds.  We                


               13  Petitioner also argues with respect to Godley Realty                 
          that its accounts receivable were not actually accounts                       
          receivable; that is, petitioner argues that they were not amounts             
          owed by Godley Realty to each housing partnership but rather were             
          distributions from Godley Realty, before it was incorporated, to              
          decedent and Fred Jr. and were incorrectly recorded as                        
          receivables held by the housing partnerships.  We reject this                 
          argument for a number of reasons.  First, the supporting evidence             
          is at best vague and imprecise.  Second, in contradiction to this             
          position, petitioner submitted an expert report that treated                  
          these amounts as accounts receivable.  Finally, petitioner                    
          allowed respondent to treat the corresponding amounts as accounts             
          payable in the hands of Godley Realty, which resulted in their                
          treatment as liabilities at face value when respondent and                    
          petitioner reached agreement on the valuation of Godley Realty.               




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