- 2 - section1 6662(a), with respect to the Estate of Pearl I. Amlie (the estate).2 After concessions, the issues remaining for decision are: (1) The fair market value of First American Bank Group, Ltd. (FABG) stock held by Pearl I. Amlie (decedent) at her death. Subsumed within this issue is the question of whether an agreement restricting the sale of decedent's FABG stock fixes the stock's value or should be disregarded in determining value for Federal estate tax purposes;3 (2) the fair market value of five parcels of agricultural real property (farm land) owned by decedent at her death; (3) whether the reimbursement by decedent's conservator, prior to decedent's death, of $30,000 of litigation expenses 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as in effect at the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 In the notice of deficiency, respondent also determined a fraud penalty of $193,391 under sec. 6663(a). Respondent has since conceded the fraud penalty and proceeds on his alternate determination of an accuracy-related penalty for negligence or disregard of rules or regulations under sec. 6662(a), confined to that portion of the underpayment arising from the value reported for decedent's FABG stock, or $51,571. 3 The estate argues, in the alternative, that if the value of the FABG stock is as determined by respondent, then the Rodney B. Amlie Trust had a claim against the estate of $495,968, deductible by the estate under sec. 2053(a)(3). As we decide this case on other grounds, we find it unnecessary to consider this argument.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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