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BEGHE, J., dissenting: Using the estate depletion approach
set forth in my dissenting opinion in Shepherd v. Commissioner,
115 T.C. ___ (2000) (slip opinion pp. 63-67), as supplemented by
my dissenting opinion in Estate of Strangi v. Commissioner, 115
T.C. (2000) (slip opinion pp. 39-48), I respectfully suggest
that the valuation focus in this case should have been on the
assets transferred by the donors, rather than on the partnership
interests received by the donees. I would have valued the gifts
at 100 percent of the values of the assets transferred to the
partnership by Mr. and Mrs. Knight, reducing the values so
arrived at by the values of the partnership interests Mr. and
Mrs. Knight received and retained.
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