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(the estate).1 After concessions,2 the issue for decision is the
fair market value on February 29, 2000, of Phases 2 and 5 of the
Langer MarketPlace Planned Unit Development.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
F. Wallace Langer (decedent), a lifelong resident of
Sherwood, Oregon, died on February 29, 2000 (the date of death).
Decedent’s nephew, Clarence D. Langer, Jr. (Clarence Langer), was
appointed executor of the estate. At the time the petition was
filed, he resided in Sherwood, Oregon.
1 Amounts are rounded to the nearest dollar.
2 The parties have stipulated: (1) The taxable estate will
be increased by $127,802, representing the value of the residence
included in the Langer Residence Revocable Trust; (2) decedent’s
29.19-percent interest in the Langer Family LLC (LFLLC) is
included in the estate; (3) the fair market value of the real
property owned by the LFLLC, excluding Phases 2 and 5 of the PUD
and prior to reduction for deferred property taxes, was
$5,885,000 on February 29, 2000; (4) the net value of the real
property owned by LFLLC will be calculated by adding the fair
market value of Phases 2 and 5 to $5,885,000, then subtracting
$430,310 to account for property tax liabilities that would
attach the property on the date of death; and (5) the value of
decedent’s 29.19-percent interest in LFLLC will be computed by
multiplying the net value of the real estate owned by LFLLC by
15.32475 percent. This computation reflects a 47.5-percent
discount to account for all applicable discounts. The figure
thus computed will be substituted for the value of decedent’s
interest in LFLLC reported on Schedule G, Transfers During
Decedent’s Life, of the estate’s Form 706, United States Estate
(and Generation-Skipping Transfer) Tax Return.
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