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Machine Works and began to be used as a machine shop. For
several years thereafter, the rental was $1,500 per month. At
decedent’s death, the highest and best use of the Richard
Property was for heavy industrial usage.
6. Other Properties
The estate includes two real properties on Lafayette Street
in Santa Clara, in addition to the Subject Properties. On the
estate tax return, these additional properties are shown as
having an aggregate date-of-death value of $230,000. In the
notice of deficiency, respondent determined an aggregate value of
$290,000. In the amended estate tax return, the aggregate value
is again shown as $230,000. The parties have stipulated that the
aggregate value of these additional properties is $220,000.
7. Valuation Conclusions
Table 2 shows the positions of the parties, of their expert
witnesses, and of the Court as to the fair market values of the
subject properties on the date of decedent’s death.
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