- 19 - Our Valuation of the California Motel At his death, decedent owned both a one-half undivided interest in parcel 2 and 50 shares of C&L Bailey stock. C&L Bailey, in turn, owned the other half of parcel 2, as well as the motel that sat upon it. The estate, being initially unaware of decedent’s individual ownership interest in parcel 2, inadvertently omitted this asset from decedent’s gross estate on the estate tax return. Petitioner now contends that this inadvertent omission should be cured by increasing decedent’s gross estate by $64,100, on the basis of Biles’ determination of the date-of-death value of decedent’s ownership interest in parcel 2. At the same time, petitioner contends, the value of the 50 shares of C&L Bailey stock included in decedent’s gross estate should be reduced from $370,708 (as reported on the estate tax return) to $194,565, to reflect the “title problem” that petitioner contends reduced the value of the California motel from $1,388,000 (as indicated by the Ohrmund report, on which the relevant values reported on the estate tax return were predicated) to $819,000 (as determined by Biles). We are unpersuaded by petitioner’s contentions. In the first instance, Biles’ conclusion that decedent’s ownership interest in parcel 2 should be valued at $64,100 appears based on an erroneous assumption that decedent owned all of parcel 2. In fact, decedent owned only a one-half undivided interest in parcelPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011