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The record contains no Forms 1065 (or other partnership tax
reporting forms) relating to the claimed family farm partnership;
at least three other pass-through entities in which decedent or
the children have an ownership interest--HEI (a subchapter S
corporation), Hendrickson Farms (a partnership), and G.O. Farms,
Inc. (an S corporation)--file Federal income tax forms.
Petitioner's purported "accounting" of Garry's estate lists
deposits made to and payments made from (other than interaccount
transfers) the following three bank accounts, which petitioner
claims were used to conduct the business of the family farm: Old
National Bank account No. 317015885 (the Garry estate account);
Old National Bank account No. 317013807 (the Vera Lou Klippel
agent account); and Old National Bank account No. 417-00-3455
(the Hendrickson Farms account). No part of any of these three
accounts was reported as an asset of decedent's estate on
petitioner's Federal estate tax return.
In 1979 (the year of Garry’s death), part of the family farm
was farmed by Garry personally, and part was farmed by tenant
farmers. Part of the family farm land was still being farmed by
tenant farmers during 1985.
For its fiscal years ending in February 1980 through
February 1986, Garry’s estate reported the following amounts of
gross farm rental income on its Federal fiduciary income tax
returns:
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