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decedent’s trust ($8,492.30 in a Merrill Lynch cash account
offset by an overdraft of $3,075.47 in the checking account); a
$169.38 cash payment due from Boston Co; and $2,918.98 in a
savings account.
On the estate tax return, Mr. Bigelow reported that
decedent’s limited partnership interest in the partnership was
worth $135,079.88. In computing that value, decedent’s estate:
(1) Computed 44 percent of $1,475,000 (the value of the Padaro
Lane property); i.e., $649,480.85, (2) subtracted $435,069.75;
i.e., the amount of the Great Western Bank loan and the Union
Bank line of credit secured by the property, and (3) applied to
the remainder a 37-percent discount for lack of marketability.
Attached to the estate tax return was a document signed by
Mr. Bigelow called “Statement As to Status of Ownership of Units”
(the statement of status), in which he certified that the
ownership of the issued and outstanding Spindrift limited
partnership units as of July 18, 1997, was as follows:
Partner A Units B Units
Decedent’s trust 1 6,450
Estate of Mrs. Fitzgerald, deceased 1 2,500
Mrs. Burke 1 2,700
Mr. Bigelow 1 1,050
Total 4 12,700
The statement of status also states that, on the valuation date,
decedent’s nine grandchildren owned the income rights associated
with 1,800 B units (200 units each) owned by the general partner.
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