- 18 - is sometimes referred to hereinafter as decedent's net investment income). The calculation is as follows: Coal royalties, dividends, interest received by Garry's estate (1979-93) $1,999,538 50 percent of above investment income, to which decedent was entitled 999,769 Less: Expenses allocable to decedent's share of investment income $72,266 Investment income distributed to decedent 14,303 86,569 Net undistributed investment income of Garry's estate to which decedent was 913,200 entitled Facts Relating to Petitioner's Primary Position--Existence of Claimed Family Farm Partnership There was no written partnership agreement between decedent and the children concerning the operation of the family farm. Petitioner’s Federal estate tax return did not report, as an asset of decedent's estate, a partnership interest in the family farm or a partnership interest of any kind. Petitioner's estate tax return reported less than $15,000 worth of farm equipment as assets of decedent's estate. All this equipment was inherited from Garry in 1979; none of it was acquired after that date. None of decedent's individual income tax returns for 1989-93 (the only income tax returns of decedent in the record) reported any income or loss from a partnership.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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