- 22 - facts of these cases would have been difficult, protracted, and expensive. The Variations Between the Estates’ Reported Values and Those Maintained for Trial Finally, we consider the escalation of the discounts claimed by the estates. John’s estate initially reported a value for the fractional interest that was discounted by only 25 percent. By the time Sarah died, the value of her fractional interest was reported at a value that was discounted by 50 percent. At that point, John’s estate amended its return and claimed a 50-percent discount. As these matters were further developed during the audit examination and controversy, information was discovered that caused the estates to further reduce the reported value of the fractional interests by claiming a 60-percent discount. Finally, the estates’ litigating position, based on Mr. Steele’s testimony, was that both fractional interests should be discounted by 90 percent. Respondent points to the escalation of the discounts and contends that it merely reflects the estates’ propensity to take aggressive and excessive positions. Respondent contends that the discount initially claimed by John’s estate was closer to the correct amount and should represent the maximum amount to which either estate should be entitled. The estates have shown, however, that the discounts initially claimed did not take intoPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011