Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor - Page 22

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          statements and a summary of liabilities to Higgins, Marcus &                
          Lovett, Inc., who prepared the appraisal (Higgins appraisal) of             
          decedent’s interest in LKHP.  The Higgins appraisal was filed               
          with the estate tax return.                                                 
               The Higgins appraisal was conducted on behalf of the estate            
          by Thomas E. Higgins (T. Higgins), an Accredited Senior Appraiser           
          of the American Society of Appraisers, and by Mark C. Higgins               
          (M. Higgins), an Accredited Member of the American Society of               
          Appraisers.  Both T. Higgins and M. Higgins specialize in the               
          business valuation discipline.  The appraisal was dated June 22,            
          1998, but valued the partnership interest as of June 5, 1997.               
          The estate’s attorney, Richard Albrecht (Albrecht), instructed              
          the appraisers to value the interest as a limited partnership               
          interest.  The Higgins appraisal reported that the fair market              
          value of decedent’s 99.95-percent limited partnership interest in           
          LKHP on June 5, 1997, was $2,266,000, after discounts for lack of           
          marketability and for lack of control.  On the estate tax return,           
          decedent’s gross estate was reported as $2,543,378.  On                     
          February 3, 1999, respondent commenced an examination of the                
          estate tax return.                                                          
          Examination                                                                 
               On February 4, 1999, the IRS sent an audit letter to Maurice           
          Polner, the accountant for the estate.  On May 23, 2001, Hillgren           
          responded to questions that were posed by IRS estate tax attorney           






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