Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 4




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               (1) Whether the values of the assets of the Sidney Gore                
          Marital Fund (Marital Fund assets) are includable in Sylvia                 
          Gore’s (decedent’s) gross estate under section 2033 or section              
          2041;                                                                       
               (2) alternatively, if decedent completed a transfer of                 
          Marital Fund assets to the Gore Family Limited Partnership (GFLP)           
          before her death, whether the values of those assets are                    
          includable in decedent’s gross estate under sections 2041, 2036,            
          and/or 2038;                                                                
               (3) alternatively, if the value of the property to be                  
          included in decedent’s estate is that of a 32.667-percent limited           
          partnership interest in GFLP, whether the value of that interest            
          on June 12, 1997, was $1,260,472, as respondent contends, or                
          $740,036, the value reported on the estate’s Federal estate tax             
          return;                                                                     
               (4) if the values of the Marital Fund assets are includable            
          in decedent’s gross estate under sections 2033, 2036, 2038,                 

               3(...continued)                                                        
          State death tax, if it is paid and claimed by the estate within             
          the period specified in sec. 2011(c)(1).                                    
               (2) Petitioner also raised the issue of whether respondent             
          erred in not applying a $192,800 Federal estate tax payment made            
          on July 14, 2000, to reduce the amount of the estate tax                    
          deficiency respondent determined in the notice of deficiency                
          dated Sept. 26, 2001.  Respondent represents that the estate’s              
          unassessed prepayment of estate tax has been credited to the                
          estate’s account and will be treated as a July 14, 2000, payment            
          in computing any outstanding estate tax liability as a result of            
          this opinion.                                                               





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