Estate of John L. Baird, Deceased, Ellen B. Kirkland and J. Samuel Baird, Co-Executors - Page 4




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          of realty and applied a 25-percent discount to account for the              
          decedent’s fractional interest.                                             
               On January 31, 1997, Sarah’s estate reported that her 17/65            
          interest in the trust had a $665,686 value.  Sarah’s estate                 
          relied on the same fair market value for the 16 parcels of                  
          realty, but used a different appraiser for the discount.  Based             
          on that appraiser’s report, a 50-percent fractionalization                  
          discount was applied to Sarah’s 17/65 interest.  On February 24,            
          1997, John’s estate filed an amended return claiming a refund on            
          the basis of the opinion used for Sarah’s estate tax return and             
          applying the 50-percent discount that had been used by Sarah’s              
          estate.  The 50-percent discount resulted in a reported value of            
          $550,378 for John’s 14/65 interest.                                         
               Respondent’s valuation engineer, a forester, also valued the           
          parcels in the course of examining the estates’ tax returns.                
          Respondent, after considering appraisals relied on by the                   
          estates’ and his own valuation engineer’s reports, issued a 30-             
          day letter, on June 26, 1998, containing respondent’s position,             
          as follows:                                                                 
               After a review of the appraisals provided by the                       
               taxpayer the engineering group recommends the timber                   
               volumes and unit prices [of the estate’s appraisal                     
               reports] be accepted.  A change to the discounts in                    
               valuing the fractional interest is recommended as per                  
               the attached report.  The service’s approach is more                   
               fully explained therein.                                               








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