- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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