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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Trust was revoked by Grantor before this conveyance.”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 (the
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Last modified: May 25, 2011