Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 34




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          (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.                                    





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