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

 

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

 

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

 

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

 

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