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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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