Estate of Ethel S. Nowell, Deceased, David A. Prechel, Personal Representative - Page 7




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          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.            






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