- 31 - In the case herein, respondent’s notice of deficiency increased the value of decedent’s interest in the Turner Partnership from $875,811, as reported on the return, to $1,717,977, and increased the value of decedent’s interest in the Thompson Partnership from $837,691, as reported on the return, to $1,396,152. Respondent explained the changes to the value of his partnership interests as follows: “The 20% minority discount and 20% lack of marketability discount has been disallowed on each of the above limited partnerships.” In addition, respondent decreased the value of decedent’s Turner Corp. stock from $5,190, as reported on the return, to $4,094, and increased the value of his Thompson Corp. stock from $7,888, as reported on the return, to $13,977. In an amendment to the answer, respondent asserted that the limited partnerships and the two family corporations should be disregarded for Federal estate tax purposes and that the property includable in decedent’s gross estate is his share of the underlying assets owned by the partnerships as of the date of his death. In the alternative, respondent asserted in the amendment to the answer that with respect to the assets transferred by decedent to the partnerships, decedent retained control and enjoyment sufficient to include the date-of-death value of those assets in the gross estate pursuant to section 2036(a). The adjustments made by respondent in the notice of deficiency resulted from respondent’s disallowance of any discounts forPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: May 25, 2011