- 9 - In effect, the amounts estimated as being due to the contractor and due to the estate from the insurance company resulted in a net reduction of approximately $120,000 in the gross estate. Considering the $612,000 inclusion and reduction of approximately $120,000, the gross estate was increased by a net amount of approximately $490,000 in connection with decedent’s interest in the partially completed residence. With respect to the $612,000 amount, respondent determined that the value of the residence, as completed, should be includable in the gross estate. Based on the $1,032,000 completed value set forth in the appraisal attached to the estate tax return, respondent determined that the gross estate should be increased by $420,000 ($1,032,000 less the $612,000 already included)3. Respondent argues that the $420,000 increase reflects decedent’s right to receive reimbursement from the insurance company for the completion of the residence. Respondent also determined that the gross estate should be increased by $122,400,4 representing the excess of the estimated amounts that may be due to the contractor over the estimated 3 A more complete discussion of how the $612,000 value was computed appears infra pp. 13-14. 4 We have referred to this difference as an “approximate” amount because it is not clear in the record how the $122,400 amount was calculated. In any event, the parties only argue about whether the $122,400 adjustment should be sustained and not about the stated amount.Page: 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