- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011