Estate of Doris F. Kahn, Deceased, LaSalle Bank, N.A., Trustee and Executor - Page 5

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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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