Estate of H.A. True, Jr. - Page 94




                                       - 176 -                                        
          Notice, AA Hypothetical Value, WMA Hypothetical Value, and                  
          Current IRS Value.  A footnote to the “Current IRS Value” column            
          in each schedule stated:  “These values reflect respondent’s                
          agreement to allow combined minority interest and marketability             
          discounts of up to 40 percent.”  For the most part, petitioners             
          prepared Exhibit 262-P and then furnished it to respondent for              
          his review and approval.  However, respondent provided                      
          petitioners with the “Current IRS Value” information and text for           
          the related footnote.                                                       
              On February 16, 1999, the first day of trial, the parties               
          filed a stipulation of facts and a supplemental stipulation of              
          facts.  The stipulations did not refer to “Current IRS Value[s]”            
          or the combined minority and marketability discounts mentioned in           
          Exhibit 262-P.  However, the stipulations stated that respondent            
          was no longer asserting adjustments in the value of transferred             
          interests in certain companies, each of which had a “Current IRS            
          Value” that approximated its “Return Value/Book Value”.                     
              Respondent’s trial memorandum, dated January 28, 1999,                  
          stated:                                                                     
                  In [his] notice of deficiency respondent allowed no                 
              discounts to the underlying values of the transferred                   
              interests.  Respondent has indicated to petitioners that                
              minority and marketability discounts of up to 40% should                
              be applied in determining the fair market values of the                 
              transferred interests.                                                  
          In addition, “Current IRS Value[s]” differed from values reported           
          in the statutory notices because the “Current IRS Value[s]”                 






Page:  Previous  166  167  168  169  170  171  172  173  174  175  176  177  178  179  180  181  182  183  184  185  Next

Last modified: May 25, 2011