- 46 - 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).Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011