- 3 - are described in our prior Memorandum Opinion, and we see no need to recite them here. Respondent determined a deficiency in petitioner's Federal gift tax after concluding that decedent did not receive full and adequate consideration for the remainder interest that he transferred pursuant to the private annuity agreement. In particular, respondent determined that petitioner: (1) Understated the value of the assets that were the subject of the private annuity agreement; and (2) erred in relying on section 25.2512-5(f) (Table A), Gift Tax Regs., to compute the value of the remainder interest transferred pursuant to the private annuity agreement. Consequently, respondent maintains that the private annuity agreement resulted in a transfer that was in part a sale and in part a gift. After concessions by both parties, the dispute concerning the value of the assets that were the subject of the private annuity agreement was narrowed at trial to the question of whether property interests in two general partnerships that decedent transferred pursuant to the private annuity agreement should be valued as general partnership interests or as assignee interests in the two general partnerships. An additional contested issue concerned respondent's determination that petitioner erred in relying on the actuarial tables found in section 25.2512-5(f) (Table A), Gift Tax Regs., in computing thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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