Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 26




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               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.                                






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