- 39 - 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.Page: 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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