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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.
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