Estate of Helen A. Deputy, Deceased, William J. Deputy, Co-Executor - Page 6

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          shares were reported as having a fair market value of $1,941,000.           
          The reduced value was based on a revised appraisal prepared by              
          Michael A. Dorman, which was attached to the amended Form 706.              
               On May 26, 1998, a Form 709, United States Gift (and                   
          Generation-Skipping Transfer) Tax Return, was filed for                     
          decedent’s tax year ended December 31, 1997.  In that return,               
          $607,040 of taxable gifts was reported.  Respondent issued a May            
          8, 2001, notice of gift tax deficiency, determining that the fair           
          market values of decedent’s gifts of interests in the Deputy FLP            
          should be increased as follows:                                             
               Date of Gift        Value Reported      Value Determined               
               May 31, 1997        $79,620             $127,680                       
          July 20, 1997            481,350             843,804                        
          July 20, 1997            62,020                   74,515                    
          Similar to the amendment of the estate tax return (Form 706), on            
          May 21, 2001, an amended Form 709 was filed for decedent’s tax              
          year ended December 31, 1997.  In that return, $570,570 of                  
          taxable gifts was reported.  The reduction in the amount of gifts           
          reported for the 1997 year was attributable to the revised                  
          appraisal reducing the value assigned to the interest in Godfrey.           
                                       OPINION                                        
               The controversy in these cases concerns the fair market                
          value of an interest in a closely held family corporation that,             
          in turn, is held by the same family’s limited partnership.                  
          Because the largest asset of the partnership is an interest in a            






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