- 15 - 13. Federal Estate Tax Return The estate timely filed a Federal estate tax return on October 16, 2002. The return failed to report the 1991 and 1999 gifts of $595,000 and $70,000, respectively. The return was prepared by Anderson and signed by John Rector as coexecutor of decedent’s estate. The Federal estate tax return reported that decedent’s gross estate on the applicable valuation date consisted of a single asset; namely, her interest in the 1991 revocable trust. The return elected the alternate valuation date of July 11, 2002, as the applicable valuation date. The return reported that the fair market value of the 1991 revocable trust as of the applicable valuation date was $4,757,325, calculated as follows: Net asset value (NAV) of RLP $8,126,579 Decedent’s interest in RLP 72.272% Decedent’s proportionate share of NAV 5,873,241 Less 19 percent for lack of control and lack of marketability 1,115,916 Discounted value of decedent’s interest 4,757,325 OPINION 1. Preface The value of an interest in property is included in a decedent’s gross estate if: (1) The decedent made an inter vivos transfer of the property; (2) the transfer was for less than adequate and full consideration; and (3) the decedent retainedPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: March 27, 2008