- 14 - On December 22, 2005, Curtis Kimball (Kimball), the estate’s new valuation expert, finalized a report in which he concluded that the estate’s Reliance shares should be included in decedent’s gross estate at the valuation date trading price discounted by 17 percent. The schedule below sets forth the percentage discount from the valuation date trading price, the discounted per share value, and the total value of the estate’s Reliance shares as reported on the estate’s Federal estate tax return, as asserted by the estate at trial, as determined in respondent’s notice of deficiency, and as asserted by respondent at trial: Discount Discounted Discounted Total From Trading Per Share Value of Estate’s Price Value Reliance Shares Estate Tax Return (Range) 20.7% $16.50 $59,420,918 Petitioner’s Expert (Kimball) 17.0% 17.27 62,209,637 Respondent’s Notice of Deficiency 8.0% 19.15 68,964,263 Respondent’s Trial Expert (Nunes) 9.0% 18.94 68,207,998 OPINION Generally, under section 2031(a) the value of a decedent’s gross estate is based on the fair market value of property owned by the decedent as of the date of death.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011