- 8 - C&L Bailey Stock In the notice of deficiency, respondent determined that the date-of-death value of decedent’s 50 shares of C&L Bailey stock was $451,263, rather than $370,708, as shown on decedent’s estate tax return. Similarly, respondent determined that the date-of- death value of the 50 shares of C&L Bailey stock includable in decedent’s estate as QTIP property under section 2044 was $451,263. In determining these values, respondent relied upon an October 1996 valuation report (the original Smith report) that had been prepared for the trust by Dennis C. Smith (Smith), a certified public accountant and certified valuation analyst in Hot Springs, Arkansas. The original Smith report concluded that the total, undiscounted fair market value of C&L Bailey as of the date of decedent’s death was $3,610,200, or $18,051 per share. Applying a 25-percent marketability discount to this indicated value, the original Smith report concluded that the date-of-death value of decedent’s 50 shares of C&L Bailey stock was $13,358 per share. In the notice of deficiency, respondent adopted Smith’s conclusions, but increased Smith’s 25-percent discount rate by an additional 25 percent, to match the 50-percent combined discount reflected on the estate tax return. Applying this 50-percent discount to the values indicated by the original Smith report,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