Conrad Janis and Maria G. Janis - Page 8

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          Based upon the Panel’s consideration of these factors, it                   
          determined that an overall weighted discount of 37 percent was              
          appropriate.  The value of the collection was subsequently                  
          further discounted to $14,500,000 (i.e., a total discount of                
          approximately 60.42 percent).  Accordingly, the IRS determined              
          that the value of the gallery was $21,630,543.                              
               On or about January 27, 1994, Conrad and Carroll, as co-               
          executors of Sidney’s estate, agreed to the adjustments made by             
          the IRS with respect to the gallery and to the additional amount            
          of tax owed by Sidney’s estate by signing a Form 890, Waiver of             
          Restrictions on Assessment and Collection of Deficiency and                 
          Acceptance of Overassessment--Estate, Gift, and Generation-                 
          Skipping Transfer Tax.  The examination of the Form 706 was                 
          concluded on or about February 2, 1994, when the IRS sent to                
          Conrad and Carroll an Estate Tax Closing Letter.  Under section             
          6501, the period of limitations for assessment against the Form             
          706 filed by Sidney’s estate expired on February 28, 1994, 3                
          years after the Form 706 was filed.                                         
          Reporting the Gallery’s Operations From 1990 Through 1997                   
               Conrad and Carroll operated the gallery through the trust              
          until November 8, 1995.  As of November 8, 1995, the trust was              
          terminated and its assets (including the gallery) were                      
          distributed to Conrad and Carroll in equal shares.  Subsequently,           
          Conrad and Carroll contributed their interests in the gallery to            






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