- 14 - sound valuation will be based upon all the relevant facts, but the elements of common sense, informed judgment and reasonableness must enter into the process of weighing those facts and determining their aggregate significance. [Id. at 526.] The Court of Appeals then emphasized that “every lawsuit is unique; thus it is incumbent on each party to supply the Tax Court with relevant evidence of predeath facts and occurrences supporting the value of the Exxon claim advocated by that party.” Id. at 526. The Court of Appeals also disagreed with our holding that the section 1341(a) income tax benefit that would arise from any payment of Exxon’s claim was an asset includable in the gross estate. The Court of Appeals concluded that the value, for estate tax purposes, of the contingent section 1341 deduction was not a free-standing asset of the estate but was one of the factors to be considered in appraising the date-of-death value eventually assigned to Exxon’s claim for purposes of the section 2053(a)(3) deduction. Id. at 528. The Court of Appeals noted: Of course, once the Tax Court determines, on remand, the gross value of the Exxon claim for purposes of section 2053(a)(3), calculation of the section 1341 income tax benefit becomes a simple mathematical calculation, the result of which will diminish the gross value of the Exxon claim, dollar for dollar, to produce a net deduction from the Estate. * * * [Id.] The Court of Appeals ultimately remanded the case for further proceedings consistent with the instructions provided in its opinion. Id. at 532.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011