- 32 - decedent’s 50 shares of C&L Bailey stock was $357,738 (see Appendix B). B. Valuation of QTIP Property As previously discussed, the parties agree that the value of the 50 shares of C&L Bailey stock includable in decedent’s gross estate pursuant to section 2044 and the value of the 50 shares of C&L Bailey stock that decedent owned outright are identical. Consequently, we hold that the 50 shares of C&L Bailey stock includable in decedent’s gross estate pursuant to section 2044 have a value of $357,738. C. Unreported Taxable Gifts The Promissory Note In 1993, decedent transferred certain of his separate property, including the Lake Catherine property, into the grantor trust. On January 31, 1994, the Manesses executed a $148,700 promissory note in favor of the grantor trust. A year later, on January 31, 1995, after decedent had revoked the grantor trust, decedent and Melba executed a warranty deed conveying the Lake Catherine property to the Manesses. On the same date, decedent and Melba executed an assignment of the promissory note to three of decedent’s children. Respondent contends that the assignment of the promissory note gave rise in 1995 to taxable gifts from decedent to three of his children in the full amount of the promissory note (lessPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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