Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 22

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          Notice of Deficiency                                                        
               On July 17, 2002, respondent timely mailed a notice of                 
          deficiency to the estate.  Therein respondent determined that the           
          value of decedent's FABG stock on the alternate valuation date              
          was $1,489,725 (its purchase price pursuant to the 1997 Rod Amlie           
          Family Agreement) and accordingly increased the taxable estate by           
          $495,968.  In addition, respondent determined the underpayment              
          arising from undervaluation of the FABG stock was attributable to           
          fraud or, in the alternative, negligence or disregard of rules or           
          regulations under section 6662.  With respect to decedent's farm            
          land, respondent determined that the fair market values on the              
          alternate valuation date were as follows:                                   
                    Parcel 1            $308,544                                      
                    Parcel 2            214,368                                       
                    Parcel 3            209,936                                       
                    Parcel 4            172,876                                       
                    Parcel 5             26,000                                       
                    Total               931,724                                       
          Respondent's determinations concerning the farm land increased              
          the taxable estate by an additional $179,003.  Finally,                     
          respondent determined that the estate failed to report $30,000 of           
          lifetime taxable gifts made by decedent.                                    
          Burden of Proof                                                             
               The revenue agent conducting the examination in this case,             
          Keith Puntenney (Agent Puntenney), initially requested                      
          information from the estate's accountant, Wesley Stille, and                







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