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Estate Tax Return and Respondent's Audit
As indicated, decedent died on December 31, 1989.
In spite of decedent's April 1986 assignment to his daughter
of a remainder interest in his ownership unit in the FC
Partnership, petitioner agrees that, for Federal estate tax
purposes and pursuant to section 2036(a)(1), the date-of-death
value of decedent's ownership unit in the FC Partnership is
includable in decedent's gross estate. Accordingly, on
petitioner's Federal estate tax return, the ownership unit was
included in decedent's gross estate at a December 31, 1989, date-
of-death value of $280,000. The record does not reflect how the
$280,000 date-of-death value was calculated.
On audit of petitioner's Federal estate tax return,
respondent determined that decedent's ownership unit in the FC
Partnership should be included in decedent's gross estate at a
December 31, 1989, date-of-death value of $721,960.
Prior to trial, both petitioner and respondent revised their
respective assertions for the December 31, 1989, date-of-death
value of decedent's ownership unit in the FC Partnership.
Petitioner now asserts that the date-of-death value of decedent's
ownership unit equaled $200,000, and respondent asserts that the
date-of-death value of decedent's ownership unit equaled
$596,000.
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