- 6 - David, all partnership income and income from other sources. She did not maintain any records to account separately for partnership and nonpartnership funds. Decedent utilized the account as her personal checking account, and from this account she paid personal and partnership expenses. Decedent's executor filed Form 706 (United States Estate (and Generation-Skipping Transfer) Tax Return) dated September 14, 1992. On that return, the estate did not include in the gross estate the value of the 66 $10,000 limited partnership interests decedent had assigned to family members. The estate did, however, include the value of the remaining partnership interests. The amounts included were based on advice from competent tax professionals and a property appraisal company. In the notice of deficiency issued to petitioner, respondent determined a $947,049 deficiency and a $189,410 accuracy-related penalty for negligence. The deficiency was based on respondent's determination that the value of the assets contributed to the partnerships was includable in decedent's gross estate. The deficiency was also based on a determination that petitioner had undervalued certain assets. The petition in this case was filed on November 30, 1995. OPINION As a preliminary matter, the parties disagree as to whether decedent owned, at the time the partnerships were funded, aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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