- 22 - 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, andPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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