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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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