Estate of Lewis A. Bailey, Deceased, Frances Jeanette Foster, Executrix - Page 8




                                        - 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