Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 32

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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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