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generated $747,816.12. After covering tax liabilities of all WCB
Holdings members, WCB Holdings and in turn ISA Trust distributed
$400,000 in four equal shares to decedent’s four children. The
ownership interests in WCB Holdings were changed so that they
were held as follows:
WCB Class A Class A Class B Class B
Holdings governance financial governance financial
member units/percentageunits/percentageunits/percentageunits/percentage
Decedent 287,620/ 48.39%287,620/ 50.2 0/ 0 0/ 0
ISA 80,860/ 13.61 59,515/ 10.39 681,060/ 12.73 659,715/ 12.38
Trust
BFLP 0/ 0 0/ 0 4,667,884/ 87.27 4,667,864/ 87.62
CH Trust 77,262/ 13 77,262/ 13.48 0/ 0 0/ 0
GC Trust 77,262/ 13 77,262/ 13.48 0/ 0 0/ 0
QTIP 71,319/ 12 71,319/ 12.45 0/ 0 0/ 0
Trust
Total 594,323/100 572,978/100 5,348,944/100 5,327,579/100
IV. The Estate of Wayne C. Bongard
The estate filed a Federal estate tax return on February 15,
2000. For Federal estate tax purposes, the estate elected the
alternate valuation date of May 16, 1999. On February 15, 2000,
the estate completed a Form 706, United States Estate (and
Generation-Skipping Transfer) Tax Return, which reported that the
Federal estate tax owed was $17,004,363. The estate attached
Schedule F, Other Miscellaneous Property Not Reportable Under Any
Other Schedule, to its Form 706. Schedule F showed the alternate
values of decedent’s WCB Holdings class A membership units and
his 91.28-percent limited partnership interest in BFLP to be
$4,193,000 and $41,329,838, respectively. On February 4, 2003,
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