- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011