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The Properties
Among the properties included in decedent’s gross estate,
the values of which are reported on decedent’s estate tax return,
are four real properties located in Santa Clara County,
California, as follows:
(1) 14521 Quito Road, Saratoga, hereinafter sometimes
referred to as the Quito Property;
(2) 2201 and 2215 Lafayette Street, Santa Clara,
hereinafter sometimes referred to as the Lafayette
Property;6
(3) 767 Parker Street, Santa Clara, hereinafter
sometimes referred to as the Parker Property; and
(4) 1061 Richard Street, Santa Clara, hereinafter
sometimes referred to as the Richard Property.
The Quito Property, the Lafayette Property, the Parker Property,
and the Richard Property are hereinafter sometimes referred to
collectively as the Subject Properties.
1. In General
The Subject Properties are south or southeast of the
southern end of the San Francisco Bay, in Santa Clara County, the
most populous county in the San Francisco Bay region. Saratoga
(the Quito Property), about 10 miles west of San Jose, is a small
city which is significantly more affluent than the county as a
whole. Saratoga is largely a “bedroom community”. Santa Clara
6 The Lafayette Property consists of two contiguous properties
that the parties treat as one property for valuation purposes in
the instant case. See supra note 4.
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Last modified: May 25, 2011