Estate of Dorothy Morganson Schauerhamer, Deceased, Karl C. Dean, Personal Representative - Page 6

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          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, a                 






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