- 22 - 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 attorneyPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011