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OPINION
Section 20011 imposes a Federal estate tax “on the transfer
of the taxable estate of every decedent who is a citizen or
resident of the United States”. The value of the gross estate
includes the value of all property to the extent of the
decedent’s interest therein on the date of death. Sec. 2033.
The term “value” means fair market value, which is defined for
Federal estate tax purposes as “the price at which the property
would change hands between a willing buyer and a willing seller,
neither being under any compulsion to buy or to sell and both
having reasonable knowledge of relevant facts.” United States v.
Cartwright, 411 U.S. 546, 551 (1973); sec. 20.2031-1(b), Estate
Tax Regs.
The parties dispute the value of the Victorville property,
which is includable in decedent’s gross estate. At trial, the
estate called B.G. Thompson as an expert valuation witness. Mr.
Thompson prepared an expert witness report, as supplemented, in
accordance with Rule 143. Respondent called Robert Perdue as an
expert valuation witness. Mr. Perdue prepared an expert witness
report, as supplemented, in accordance with Rule 143. In
addition, the estate sought testimony from Mr. Dicker as to his
opinion of the value of the Victorville property. While expert
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011