- 8 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011