- 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).
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