- 4 - O.E. Williams has continually managed the trust properties since the 1970s, and it was expected that he would continue to do so. O.E. Williams generally did not consult with his cotrustees and/or family members in the management of the trust timberland. His independent management was not necessarily in accord with the best management practices. Reported in John’s estate was his undivided one-half community property interest in the 14/65 interest in the trust at a value of $707,972, after applying a 25-percent fractionalization discount. In an amended return for John’s estate, a refund was claimed on the basis of an increased fractionalization discount of 50 percent. Ultimately, a 60- percent discount was claimed by John’s estate. The 14/65 interest after applying a 50-percent discount was returned at $550,378. After applying a 60-percent discount the reported amount would have been reduced to $504,610.37. Sarah’s 17/65 interest was reported in her estate’s tax return at a value of $665,686, after applying a 50-percent fractionalization discount. In an amended return for Sarah’s estate, a refund was claimed on the basis of a 60-percent increased fractionalization discount, which resulted in a reported value of $449,456.27. Respondent determined that John’s 14/65 interest had a date of death fair market value of $975,091. Respondent determinedPage: 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