- 7 - value of the partnerships. The following chart sets forth the Federal estate tax values of the partnership interests as represented in the United States Estate Tax Return. Ownership Estate Tax Partnership Interest Units Value Discount PFLP in Revocable trust 1,386,500 $298,100 65% ESNGLP in Revocable trust 75,000 31,900 50% PFLP in QTIP trust-nonexempt408,000 125,300 50% PFLP in QTIP trust-exempt 200,000 43,000 65% ESNGLP in QTIP trust-exempt 200,000 85,000 50% On examination, respondent determined that the partnership interests that were held by the revocable trust and the QTIP trusts should be merged for valuation purposes. Accordingly, respondent determined that the value of the partnership interests in the revocable trust should be increased by $577,300 and that the value of the partnership interests in the QTIP trusts should be increased by $272,404. Respondent also added $2,500 to decedent's gross estate for a 1992 Federal income tax refund. The resulting deficiency in Federal estate tax was determined to be $342,688. Discussion Partial summary judgment is appropriate when the record shows that there is no genuine issue of material fact and that a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011