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concludes that the fair market value of a 1-percent “assignee’s
interest in the Class B Limited Partnership Interests” as of June
25, 1996 was $93,540. CFT and the symphony raised no objections
to the value found in the HFBE letter and accepted $338,967 and
$140,041, respectively, in redemption of their interests.
The Gift Tax Returns
Petitioners timely filed Forms 709, United States Gift (and
Generation Skipping Transfer) Tax Return, for 1996 (the Forms
709). In schedules attached to the Form 709, petitioners
reported a gross value of $3,684,639 for their respective shares
of the gifted interest. Each petitioner reduced that amount by
the amount of Federal and State (Louisiana) gift tax generated by
the transfer that the children agreed to pay as a condition of
the gift. Each petitioner further reduced that amount by a
computation of the actuarial value, as of the valuation date, of
the contingent obligation of the children to pay (again, as a
condition of the gift) the additional estate tax that would
result from the transaction if that petitioner were to die within
3 years of the valuation date. Based on those adjustments, Mr.
and Mrs. McCord reported total gifts of $2,475,896 and
$2,482,605, respectively.3 Mr. and Mrs. McCord each claimed an
annual exclusion amount of $60,000 and a charitable contribution
3 Those figures also reflect cash gifts of $10 by each
petitioner to nominally fund the trusts.
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