Estate of Georgina T. Gimbel, Deceased, Janet G. Rogers, JoAnne M. Gimbel, and Thomas W. Gimbel, Co-Executors and Co-Trustees - Page 14

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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                  

               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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Last modified: May 25, 2011