# United States v. Godley - Computation Exhibit 1

United States v. Estate of Fred O. Godley

Computation Exhibit 1

Hypothetical Original Return Figures - Minimum Amount Necessary For a §6166 Election

(See the United States v. Godley case description from which these numbers are drawn.)

 Hypothetical Original Estate Tax Return Figures 2,424,526.00 Gross estate (given) 1,000,654.00 Schedules J, K, and L deductions 1,423,872.00 Taxable estate 0.00 Adjusted taxable gifts 1,423,872.00 Total amount drawing tax 523,065.00 Tentative tax 192,800.00 Unified credit 330,265.00 Tax before state death tax credit 59,528.00 State death tax credit 270,737.00 Net estate tax (given)

 Hypothetical §6166(b)(6) Adjusted Gross Estate 2,424,526.00 Gross estate (given) 1,000,654.00 Schedules J, K, and L deductions 1,423,872.00 Taxable estate and Adjusted Gross Estate

 §6166(a)(2) Qualified Business Ratio - 6 Decimal Places 498,356.00 Minimum qualifying §6166 business value, divided by 1,423,872.00 §6166(b)(6) adjusted gross estate, yields .350001 The minimum §6166(a)(2) qualifying ratio carried to 6 decimal places

 §6166(a)(2) Qualified Business Ratio - 2 Decimal Places 512,594.00 Minimum qualifying §6166 business value, divided by 1,423,872.00 §6166(b)(6) adjusted gross estate, yields .36 The minimum §6166(a)(2) qualifying ratio rounded to 2 decimal places

 Minimum Amount of Tax Deferred Under §6166 270,737.00 Estate tax assessed on the original return .350001 Minimum §6166(a)(2) qualifying ratio 94,758.00 Minimum amount of original tax eligible for deferral under §6166