Estate of Ona E. Hendrickson - Page 40





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          contribute their shares of the investment income of Garry's                  
          estate to the partnership, to be used as necessary to support the            
          farming activities.  Petitioner further asserts that, as matters             
          turned out, decedent's $913,200 of investment income was in fact             
          contributed to the partnership to support the losses of the farm             
          operations.                                                                  
               As an initial response to petitioner’s argument, we note                
          that there was no written partnership agreement among decedent               
          and the children concerning the operation of the family farm.  In            
          addition, the record contains no Forms 1065 (or other partnership            
          tax reporting forms) relating to the claimed family farm                     
          partnership--although at least three other pass-through entities             
          in which decedent or the children had an ownership interest filed            
          Federal income tax forms.                                                    
               We also note that petitioner's Federal estate tax return did            
          not report, as one of the assets of decedent's estate, a                     
          partnership interest in the family farm.  It also did not report             
          as an asset any of the three bank accounts petitioner claims were            
          used to conduct the business of the farm partnership.  Moreover,             
          with respect to any equipment of the partnership, petitioner's               
          estate tax return reported less than $15,000 worth of farm                   
          equipment as assets of decedent's estate, all of which had been              
          inherited by decedent from Garry in 1979.  Furthermore, with                 
          respect to any income or loss of the claimed farm partnership,               





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