- 26 - On August 7, 1996, because the estate contained insufficient assets to fund all bequests in decedent’s will, an assignment of partnership interest in the Turner Partnership was executed between decedent’s estate and Betsy’s five grandchildren, transferring partial interests in the Turner Partnership to them. B. Estate Tax Return A Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, was filed on February 21, 1996. A supplemental estate tax return was filed on December 10, 1996. On the return, decedent’s estate reported that decedent held an 87.65-percent interest in the Turner Partnership (with a value of $875,811) and a 54.12-percent interest in the Thompson Partnership (with a value of $837,691). The return reported that decedent held 490 shares of Turner Corp. stock valued at $5,190 and 490 shares of Thompson Corp. stock valued at $7,888. The values reported on the return were determined by applying a 40-percent combined discount for minority interest and lack of marketability to the net asset value of the assets of the partnerships. The estate tax return reported $19,324 as prior adjusted taxable gifts pursuant to section 2001(b) related to decedent’s gifts of the partnership interests in the Turner Partnership and the Thompson Partnership. The value of the prior gifts had also been determined by applying a 40-percent combined discount for minority interest and lack of marketability.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011