Estate of Lewis A. Bailey, Deceased, Frances Jeanette Foster, Executrix - Page 39




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                                     APPENDIX A                                       
                            Net Asset Value of C&L Bailey                             
                             Estate Tax                                              
                                Return     Petitioner    Respondent    Holding       
     Assets                                                                           
     Arkansas Motel           1$2,400,730   $2,380,000    $2,380,000 $2,380,000       
     California Motel         1,388,000    819,000        1,388,000  1,388,000        
     Other assets              430,198          2-–         3202,252    202,252       
     Total assets             $4,218,928    $3,199,000    $3,970,252 $3,970,252       

     Liabilities                                                                      
     Loans from stockholders      4-–    145,000       -- --                          
     Other liabilities         4-–           1,108,349     1,108,349  1,108,349       
     Total liabilities        $1,253,266    $1,253,349    $1,108,349 $1,108,349       
     Net assets               $2,965,662    $1,945,651    $2,861,903 $2,861,903       

          1 The estate tax return includes a $20,730 addition to the value of the     
     Arkansas motel described only as “Godbehere Appraisal.”  The record is           
     silent as to what this amount represents.  Neither party has included such       
     a separate amount in their calculations, and we ignore it in our holding.        
          2 On brief, petitioner omits from her net asset value calculations all      
     assets other than the motels.  Because petitioner has not otherwise              
     disputed the existence or amounts of other assets as reported on the estate      
     tax return, we assume that the omission was inadvertent and deem petitioner      
     to have conceded the values of other assets in the lesser amounts                
     determined by respondent.                                                        
          3 Respondent’s $202,252 of other assets consists of $104,816 cash,          
     $29,697 accounts receivable, $42,574 mortgage and real estate loans, and         
     $25,165 other current assets.  All these amounts are as reflected on C&L         
     Bailey’s Dec. 31, 1995, balance sheet.  Respondent has excluded $19,000          
     franchise fees deposits and $16,316 loans to stockholders as shown on the        
     corporate balance sheets.                                                        
          4 The estate tax return provides no detail as to the types of               
     liabilities included in the net asset value calculation.                         









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