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beneficiaries. The estate did not report the value of the
Rothschild IRA on the original tax return. On the amended estate
tax return, the estate reduced the value of the Rothschild IRA by
22.5 percent to $1,000,574 to reflect the income tax liability
upon the distribution of its assets to the beneficiaries.
Respondent determined in the notice of deficiency an estate
tax of $843,892.3 The estate’s motion for partial summary
judgment was filed on June 30, 2005, and on June 30, 2005,
respondent’s cross-motion for summary judgment was filed seeking
summary adjudication on the following issues: (1) Whether the
value of each IRA is less than the value of the NAVs, and (2)
whether the estate properly deducted amounts not paid for
estimated Federal income tax liabilities of decedent. The estate
filed a reply in opposition to respondent’s cross-motion for
summary judgment; however, the estate did not address the second
issue regarding the validity of the estate’s deduction. We
therefore consider this issue to be conceded by the estate.
3The only portion of the deficiency that is in dispute is
the amount attributable to the valuation of the IRAs. In the
Form 886-A, Explanation of Adjustments, respondent determined
that the value of the Harris IRA should be increased from
$1,086,044 to $1,401,347 “to more accurately reflect the fair
market value of this asset at the date of death under secs. 2031
and 2039 of the Internal Revenue Code.” Further, respondent
determined that the value of the Rothschild IRA should be
reported at $1,219,063. The Rothschild IRA was omitted from the
original Federal estate tax return. The parties have stipulated
the settlement of the remaining issues pertaining to the notice
of deficiency that the estate raised in its petition.
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