- 34 - (2) $110,500 cash to the Michael Gore Trust; (3) a 1-percent general partnership interest in GFLP to the Pamela Powell Trust, valued at $34,627; (4) a 1-percent general partnership interest in GFLP to the Michael Gore Trust, valued at $34,628; (5) a 32- percent limited partnership interest in GFLP to the Michael Gore Trust, valued at $503,834; and (6) a 32-percent limited partnership interest in GFLP to the Pamela Powell Trust, valued at $503,834. Ms. Bowers relied solely on the assignment to conclude that decedent had made completed gifts on January 8, 1997. Ms. Bowers relied on a valuation opinion letter dated February 17, 1997, from K. Scott Sallee of Baird, Kurtz & Dobson to calculate the value of the gifts reported on Form 709.32 In the opinion letter, Mr. Sallee concluded that, after subtracting the $200,000 that was supposed to have been transferred to the Pamela Powell and Michael Gore Trusts, the total value of GFLP was $4,266,627.33 Mr. Sallee then applied a combined discount for lack of control and marketability of 55 percent to compute an “adjusted aggregate nonmarketable and noncontrolling” value for 32Each page of the valuation opinion attached to Form 709 was stamped with the following: “Preliminary Draft For Discussion Purposes Only”. 33Although the funds to complete the gifts of $100,000 to each of the Pamela Powell and Michael Gore Trusts were never transferred from the Marital Fund to TCO, respondent has not argued that these gifts were incomplete.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: November 10, 2007