Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 46




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                                     7/93                   5/15/95                   
            Shares      Value        Shares       Value                               
          New assets                                                                  
          First National Bank account                                                 
          General   ---   ---     ---        3,404                                    
          Lewisville   ---   ---     ---        1,479                                 
          Real Property                                                               
          Lewisville property   ---   ---     ---   154,500                           
          Cash value life insurance                                                   
          George   ---   ---     ---  8,907                                           
          Betsy   ---   ---     ---  1,821                                            
          Total                                                10,728                 
          Unearned premium--                                                          
            life insurance   ---   ---     --- 15,905                                 
          Loans receivable                                                            
          William Turner, IV   ---   ---     --- 13,171                               
          Robert & Lorraine Turner   ---   ---     ---   $48,275                      
          Bill’s Bloom, Inc.   ---   ---     ---     8,000                            
          Accrued int. & div.   ---      ---     ---         3,032                    
          Unattributed total                                   258,494                
            Total assets                1,460,670              1,751,986              
               The securities totaling $1,232,076 were assets transferred to          
          the Turner Partnership by decedent.  In addition to those                   
          securities, new assets that derived from assets transferred by              
          decedent are included in decedent’s taxable estate under section            
          2036(a).  The Lewisville Property was funded with the margin loan           
          attributable to the securities contributed by decedent.  None of            
          the real estate contributed by George to the partnership produced           
          any income.  At most, the $1,479 in the Lewisville Properties               
          account could be attributed to the $1,000 contributed by George on          
          the formation of the partnership.  The remaining $257,015 ($258,494         
          - $1,479) of the new assets held by the partnership at decedent’s           
          death must have derived from the assets contributed by decedent.            
          We find, therefore, that assets totaling $1,489,091 ($1,232,076 +           
          $257,015) held by the Turner Partnership at the date of decedent’s          
          death are included in the taxable estate under section 2036(a).             





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