- 13 - We find that the estate did not adequately determine reasonable prices at which the five advertised properties could sell. Asked how prices were calculated, Mr. Renbarger stated simply that he put a figure on them and waited for an offer to come along. One witness for the estate testified that little research was conducted to ascertain proper sales prices and that Mr. Renbarger would merely declare a price and place a “for sale” sign on the property. These arbitrary price determinations are exemplified by one property’s being priced at three times the value at which it was reported on the estate’s Federal estate tax return.7 While the Court does not begrudge Mr. Renbarger’s attempt to profit from sales of estate property, he cannot do so and simultaneously urge the Court to find that the estate faced an undue hardship because it could sell only at sacrifice prices. See sec. 20.6161-1(a)(2)(ii), Example (2), Estate Tax Regs. No undue hardship exists where a taxpayer can sell at current market values. See sec. 1.6161-1(b), Income Tax Regs. (if a market exists, the sale of property at the current market price is not ordinarily considered an undue hardship). Mr. Renbarger has failed to demonstrate that he ever offered the five properties at 7The reported value of the Garden Ridge Property in the estate’s Federal estate tax return was $1,294,700. The asking price was approximately $3,833,000.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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