- 2 - 6251-00, and a Federal estate tax deficiency of $143,932 relating to docket No. 6262-00. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues are the valuation of certain retained and gift interests in a Family Limited Partnership (FLP) and liability for the section 6651(a) addition to tax. FINDINGS OF FACT When the petitions were filed, K. Robert Dailey II was a resident of Harris County, Texas, where, in 1997, his mother, Elma Middleton Dailey, had died, and Mr. Dailey had received an appointment to be her executor. On December 2, 1982, Mrs. Dailey’s husband died, leaving to her, among other things, the following: Number of Value per Total Company Shares Share Value Exxon Corp. 11,108 $33.63 $373,562 American Telephone & Telegraph Co. (AT&T) 400 65.75 26,300 On October 20, 1992, Mrs. Dailey executed a will, a Revocable Living Trust (Trust), and an Agreement of Limited Partnership (Agreement) of Elma Middleton Dailey FLP. The will provided that Mrs. Dailey’s residuary estate would pass to the Trust, from which her son would receive the corpus outright. Upon execution of the Agreement, Mrs. Dailey took a 1- percent general and a 98-percent limited partnership interest,Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011