Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor - Page 24

                                       - 24 -                                         
               On August 24, 2001, a notice of deficiency was sent to the             
          estate.  The notice increased the value of decedent’s interest in           
          LKHP.  The notice determined decedent’s 99.95-percent interest in           
          LKHP to be valued at $4,526,740 based upon the undiscounted                 
          values of the LKHP properties.  The notice determined a                     
          deficiency in the estate tax of $1,269,498.  The increased                  
          values, as determined in the notice, were not supported by                  
          independent appraisals because LKHP was not recognized as a valid           
          partnership entity.                                                         
          Value of the LKHP Properties as Agreed by the Parties                       
               The parties have stipulated the undiscounted values of                 
          decedent’s interest in the seven LKHP properties as follows:                
                    Property                    Value                                 
                    West Collins             $1,285,000                               
                    Enterprise               1,093,787                                
                    North Main               975,000                                  
                    University property      1,074,131                                
                    Manzanita                     2,261                               
                    Crescent Bay             265,176                                  
                    Railroad                 115,711                                  
                    Total                    $4,811,066                               
                                       OPINION                                        
          Burden of Proof                                                             
               Generally, under section 7491(a), in any court proceeding,             
          if a taxpayer introduces credible evidence with respect to any              
          factual issue, the burden of proof is shifted to respondent.  The           
          burden shifts, however, only when the taxpayer has maintained all           
          records and has cooperated with reasonable requests by respondent           





Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011