Estate of Mildred Green, Deceased, Thomas R. Green, Executor - Page 6

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          of the United States Bankruptcy Code.  On September 12, 1997,               
          counsel for Royal Banks filed a notice of appearance in the                 
          voluntary bankruptcy case.                                                  
          Decedent’s Estate Tax Return                                                
               On November 9, 1998, the estate filed a Form 706, United               
          States Estate (and Generation-Skipping Transfer) Tax Return,                
          reporting a gross estate of $3,331,853.  The estate included                
          decedent’s 3,276 shares of RBI stock in the gross estate at an              
          estate tax value of $163,800, or $50 per share.  The estate                 
          claimed a charitable contribution deduction of $1,565,678 for the           
          bequest to the Lubin-Green Foundation.  On Schedule R,                      
          Generation-Skipping Transfer Tax, the estate reported the                   
          property transferred in trust to decedent’s grandchildren as a              
          direct skip with an estate tax value of $1,565,678.  In reporting           
          these amounts, the estate allocated and charged all estate                  
          (Federal and Missouri) and GST tax to the portion of the estate             
          that passed in trust to decedent’s grandchildren.                           
          Notice of Deficiency                                                        
               On August 30, 1999, respondent commenced an examination of             
          the estate and GST tax return.  By notice of deficiency,                    
          respondent determined a $1,205,541 deficiency in the estate and             
          GST tax.  Respondent determined that at the date of decedent’s              
          death the fair market value of the 3,276 shares of RBI stock was            
          $1,048,320, rather than $163,800, as shown on the estate’s tax              






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