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includable in the gross estate pursuant to section 2044 should be
merged or aggregated with the partnership interests includable in
the gross estate pursuant to section 2038, for valuation
purposes; and (2) whether the interests in two partnerships
passing at death should be valued for Federal estate tax purposes
as "assignee" interests or as partnership interests.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
Decedent died on December 22, 1992, a resident of Arizona.
She was survived by Nancy Prechel, decedent's only child from a
prior marriage, and by David A. Prechel (Mr. Prechel) and Diane
D. Prechel (Ms. Prechel), decedent's only grandchildren.
Mr. Prechel, a resident of Arizona, was decedent's personal
representative when the petition in this case was filed.
Prior to January 18, 1991, decedent's assets consisted of
her undivided one-half community property interest in certain
publicly traded securities and real property. These assets were
held in the Ethel S. Nowell Trust (the revocable trust) that was
established on April 20, 1990. Mr. Prechel and Ms. Prechel were
named as cotrustees of this trust.
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