- 10 - $250,000, $400,000, and $100,000, respectively. In January 1997, SFLP increased John Strangi’s line of credit to $350,000 and Albert T. Strangi’s line of credit to $650,000. In November 1997, SFLP advanced to decedent’s estate $2.32 million to post bonds with the Internal Revenue Service and the State of Texas in connection with the review of decedent’s estate tax return. In 1998, SFLP made distributions of $102,500 to each of the Strangi children. The Strangi children had received $2,662,000 in distributions from SFLP as of December 31, 1998. Estate Tax Return On January 16, 1996, decedent’s Form 706, United States Estate (and Generation Skipping Transfer) Tax Return (estate tax return), was filed by Mr. Gulig. On the estate tax return, decedent’s gross estate was reported as $6,823,582. This included a $6,560,730 fair market value for SFLP. For purposes of the estate tax return, SFLP was valued by Appraisal Technologies, Inc., on an “ongoing business”, “minority interest basis”. The valuation report arrived at a value before discounts and then applied minority interest discounts totaling 33 percent for lack of marketability and lack of control. The estate tax return also indicated that decedent had $43,280 in personal debt and other allowable deductions totaling $107,108, leaving a reported taxable estate of $6,673,194. The estate tax return reported a transfer tax due of $2,522,088. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011