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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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