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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.
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