- 7 - original Biles report), prepared by Ralph W. Biles, an Arkansas State certified general appraiser, appraising the fair market value of the Arkansas motel to be $2,380,000; and (2) a March 1996 report (the Ohrmund report), prepared by Ronald D. Ohrmund, a California certified general appraiser, appraising the fair market value of the California motel to be $1,388,000. When the estate tax return was filed, the executor of decedent’s estate was unaware of decedent’s individual one-half ownership interest in parcel 2. Consequently, this asset was not separately reported on the estate tax return. Similarly, decedent’s one-half ownership interest in parcel 2 was not taken into consideration in the Ohrmund report’s valuation of the California motel or otherwise reflected in the valuation of decedent’s C&L Bailey shares as reported on Form 706. The Promissory Note On decedent’s estate tax return, the $148,700 promissory note was listed on Schedule E–-Jointly Owned Property, as decedent’s and Melba’s joint property; consequently, a one-half interest in the promissory note ($74,350) was reported as being included in decedent’s gross estate. Notice of Deficiency On or about June 13, 1997, respondent commenced the examination of decedent’s estate tax return. On July 2, 1999, respondent issued the notice of deficiency.Page: 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