- 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 Next
Last modified: November 10, 2007