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After concessions by decedent’s estate, the issue remaining
for decision is whether decedent’s gross estate includes (1) the
value of interests in two family limited partnerships (namely, the
Thompson Turner Family Limited Partnership (the Turner Partnership)
and the Thompson Family Limited Partnership (the Thompson
Partnership)), and in the respective corporate general partners of
those partnerships that decedent possessed at death or transferred
prior to death (and if so, the value of those interests), or (2)
pursuant to section 2036(a), the value of the property which
decedent transferred to the family limited partnerships and to the
respective corporate general partners of those partnerships (and if
so, the value of such property).
All section references are to the Internal Revenue Code as
amended and in effect as of the date of decedent’s death, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulations of facts and exhibits submitted therewith are
incorporated herein by this reference.
I. Background
Decedent was a resident of the State of Delaware at the time
of his death on May 15, 1995. Decedent’s estate was administered
in Delaware. Betsy Thompson Turner, decedent’s daughter and
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