Estate of John L. Baird - Page 2




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          above-captioned estates.1  For the Estate of John L. Baird,                 
          respondent determined an estate tax deficiency of $104,765.  For            
          the Estate of Sarah W. Baird, respondent determined an estate tax           
          deficiency of $240,282.  The sole remaining controversy concerns            
          the value, at their respective dates of death, of each decedent’s           
          fractional interest in a family trust holding timberland.2                  
                                  FINDINGS OF FACT                                    
               John L. Baird and Sarah W. Baird were married at all                   
          pertinent times.  John died on December 18, 1994.  Sarah died               
          less than 1 year later, on November 2, 1995.  At all pertinent              
          times the coexecutors and decedents resided in Louisiana.  At               
          their respective times of death, John held a 14/65 interest and             
          Sarah a 17/65 interest in a trust owning 16 noncontiguous tracts            
          of timberland, comprising 2,957 acres in Sabine Parish,                     
          Louisiana.  As of December 18, 1994, the undivided fee interest             
          in the 16 parcels of timberland had a fair market value of                  
          $4,685,333.  As of November 2, 1995, the undivided fee interest             


               1 These cases were consolidated for purposes of trial,                 
          briefing, and opinion.                                                      
               2 In addition to the valuation issues for each estate, the             
          parties must also reach agreement on the computation of the                 
          allowable amount of administration expenses and the amount of the           
          credit, if any, allowable to the Estate of Sarah W. Baird.  The             
          parties have settled several other matters concerning increases             
          and/or reductions to the gross estate of the Estate of John L.              
          Baird, and all these matters will be left for the Rule 155 phase            
          of this case.  All Rule references are to the Tax Court Rules of            
          Practice and Procedure.                                                     





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