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G. Tax Returns
The partnership filed income tax returns (Forms 1065, U.S.
Partnership Return of Income) for 1993, 1994, 1995, 1996, and
1997. The trust filed income tax returns (Form 1041, U.S.
Fiduciary Income Tax Return) for 1994, 1995, 1996, and 1997.
In March 1994, decedent and his children, as executors,
filed a Federal estate tax return for Mrs. Reichardt's estate in
which they reported a gross estate of $1,092,290. Hannah
prepared the return.
Decedent filed a Federal gift tax return for 1993 on April
15, 1994. In it, he reported that he had given a 30.4-percent
interest in the partnership to each of his two children and that
each gift had a value of $310,000 as of October 22, 1993.
After decedent died, petitioner obtained an appraisal of
decedent’s estate and the 1993 gifts. On Schedule F of the
estate tax return, petitioner reported that, when decedent died,
his gross estate included a 36.46-percent limited partnership
interest in the partnership which had a fair market value of
$346,000, and a 1-percent general partnership interest in the
partnership which had a fair market value of $13,000.
OPINION
A. Section 2036(a)
A decedent’s gross estate includes the value of property
interests transferred by the decedent during his or her lifetime
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