Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 2




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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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