- 6 - real property was previously held in the grantor trust, “which Trust was revoked by Grantor before this conveyance.” Also on January 31, 1995, decedent and Melba executed an assignment of the promissory note to three of decedent’s children (Harold, Roger, and Frances). Decedent’s Estate Tax Return C&L Bailey Stock On Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, Schedule B--Stocks and Bonds, the value of decedent’s 50 shares of C&L Bailey stock was reported as $370,708. Similarly, on Schedule F–-Other Miscellaneous Property Not Reportable Under Any Other Schedule, the value of the 50 shares included in decedent’s gross estate as QTIP property was reported as $370,708. Supporting schedules attached to the Form 706 indicate that $370,708 represents 25 percent of an indicated $2,965,662 total “liquidation value” of the two motels, after applying a 50-percent discount, described on the schedules as a “Key Man, Minority Ownership, Lack of Market Discount”. The $2,965,662 total “liquidation value” of the two motels (as indicated on the schedules to decedent’s Form 706) represented the estimated value of C&L Bailey’s assets (primarily the California motel and the Arkansas motel) net of corporate liabilities. For this purpose, the estimated value of the motels was based on two appraisal reports: (1) A May 1996 report (thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011