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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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