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acres of ranch land adjacent to the subdivision land and
constituting the greater part of what was known as the Abagail
ranch (the Abagail ranch).
There is no accompanying schedule to the Form 706 that
describes certain personal equipment used in connection with the
Abagail ranch (the ranch equipment).
Notice
Among the adjustments giving rise to respondent’s
determination of a deficiency in Federal estate tax are
adjustments increasing the value of the gross estate for the
value of the Abagail ranch and the ranch equipment. Respondent
made those adjustments on the basis that decedent owned the
Abagail ranch and the ranch equipment on the date of his death.
Petition
Among petitioner’s assignments of error in the petition are
the following:
(a) The Commissioner erroneously determined that the
gross estate includes the value of the land,
improvements and water rights of the real property
known as the Abagail Ranch, which real property was
sold to the decedent’s daughter on November 16, 1981.
(b) The Commissioner erroneously determined that
such sale to the decedent’s daughter was null and void.
* * * * * * *
(e) The Commissioner erroneously determined that the
gross estate includes the value of farm machinery and
equipment which was sold to the decedent’s daughter on
or before August 18, 1995.
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