Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 45

                                       - 45 -                                         
          FSA are comparable to similar arrangements that would have been             
          entered at arm's length.  The value of the FACC option was less             
          clear in 1995, and the conservator (as decedent's fiduciary) and            
          the prospective heirs other than Rod preferred to secure an                 
          agreement in 1995 rather than risk a protracted dispute with                
          FABG, for the reasons previously discussed.                                 
               Finally, FABG's purchase of the FABG stock from the Rod                
          Amlie Family pursuant to the 1997 Rod Amlie Family Agreement was            
          conditioned upon the sale by Rod's wife Sally of certain other              
          FABG stock that she owned in her own right, suggesting that the             
          1997 price was also affected by FABG's desire to obtain                     
          additional stock in the hands of another minority holder.                   
          Conclusion                                                                  
               We accordingly find on this record that the estate has shown           
          that the requirements of section 2703(b) are satisfied, so that             
          section 2703(a) does not provide a basis for disregarding the               
          1995 FSA.  As a consequence, we conclude that the value of                  
          decedent's FABG stock as of the alternative valuation date was              
          limited as a result of the 1995 FSA to $993,757, the value                  
          reported by the estate.                                                     
          III.  Fair Market Value of Farm Land                                        
          Background                                                                  
               The estate reported values for decedent's farm land based on           
          an appraisal by an auctioneer.  Respondent determined                       






Page:  Previous  35  36  37  38  39  40  41  42  43  44  45  46  47  48  49  50  51  52  53  54  Next

Last modified: May 25, 2011