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 |