Estate of Ona E. Hendrickson - Page 18




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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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