Estate of Nora Kolczynski, Deceased, Matthew Hoffmeier, Executor - Page 4

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               Colleton County was ranked 21st in population growth in                
          South Carolina, with an 11.3-percent increase during the period             
          1990 through 2000.  There are neither zoning nor use restrictions           
          in Colleton County.                                                         
               The parties stipulate that DP comprises 2,095.12 acres. The            
          record establishes that the main tract is 1,931.30 acres, and the           
          five smaller tracts total 133.82 acres.2  DP is north of U.S.               
          Highway 17 and south of the Ashepoo River and is bisected east to           
          west by Clover Hill Road.  DP features timberlands, open fields,            
          access to a shallow branch of the Ashepoo River, and 226 acres of           
          what were historically rice fields.  The rice fields have not               
          functioned as such for decades and no longer have dikes to                  
          regulate water flow from tidal changes.  DP is inhabited by an              
          array of wildlife including deer and migratory water fowl.                  
          Procedural History                                                          
               On September 30, 2003, respondent issued a notice of                   
          deficiency in which he determined a Federal estate tax deficiency           
          of $843,146.  The deficiency included three increases to the                
          value of decedent’s taxable estate:  (1) A $157,500 increase to             
          the fair market value of decedent’s residence; (2) a $1,112,979             
          increase to the fair market value of DP (a total value of                   
          $5,490,992); and (3) a $390,315 increase for the disallowance of            
          executor’s commissions and attorneys’ fees.                                 

               2The record does not explain the 30-acre discrepancy.                  




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Last modified: May 25, 2011