Estate of Gladys J. Cook - Page 5

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          Burns valued the lottery payments at $5,762,7913 and decedent’s             
          interests in the partnership at $2,406,413.  The experts used               
          various methods, excluding the annuity tables, to establish the             
          value of the lottery payments to the partnership.                           
               The parties have stipulated that if the final judicial                 
          determination requires application of the annuity tables, then              
          the value of the estate’s interests in the partnership will be              
          $2,908,605.  If the final judicial determination is that the                
          application of the annuity tables is not required, then the value           
          of the estate’s interests in the partnership will be $2,237,140.            
               Section 2001 imposes a tax on the taxable estate of every              
          decedent who is a citizen or resident of the United States.  See            
          sec. 2001; Estate of Kyle v. Commissioner, 94 T.C. 829, 838                 
          (1990).  The term “taxable estate” is defined in section 2051 as            
          the value of the “gross estate” less applicable deductions.  Sec.           
          2051; Estate of Kyle v. Commissioner, supra at 838.  Under                  
          section 2031(a), the gross estate includes the value at the time            
          of death of “all property, real or personal, tangible or                    
          intangible” to the extent provided in sections 2033 through 2045.           
          Estate of Young v. Commissioner, 110 T.C. 297, 306 (1998); sec.             
          20.2031-1(a), Estate Tax Regs.                                              

               3 Respondent’s expert valued the lottery payments without              
          the use of the valuation tables in the event that departure from            
          the valuation tables is warranted.                                          

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