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tax valuation understatement.1 The issues for decision are:
(1) The fair market value at the date of decedent’s death of
undivided fractional interests in two parcels of real property
held in a qualified terminable interest property trust (QTIP
trust) in which decedent had an income interest for life.
Subsumed in this issue is whether these undivided fractional
interests include interests in certain timber and pecan orchards
located on the parcels; and (2) whether petitioner is liable for
a penalty under section 6662(g).
FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate in our findings by this reference.
Decedent
On December 26, 1993, Augusta Porter Forbes (decedent)
died. At the time of her death, she resided in Atlanta, Georgia.
Her estate was administered in Fulton County, Georgia.2
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 The record does not conclusively establish the residence
or principal place of business of the executor of decedent’s
estate, Frederick W. Orr, Jr., as of the date the petition was
filed. The petition provides only the executor’s mailing address
in care of a law firm in Atlanta, Georgia. Decedent’s amended
Form 706, United States Estate (and Generation-Skipping Transfer)
Tax Return, signed Sept. 23, 1997, lists the executor’s address
as a Cashiers, N.C., post office box.
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