Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 31




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               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 for                




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Last modified: May 25, 2011