Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 48




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                 7/93                     5/15/95                                     
                                Shares      Value     Shares     Value               
          Ranch in Norwood, CO        ---       460,000         ---       595,000     
          Robert’s total                   832,808               907,144              
          New Assets                                                                  
          Cash       --- ---   ---  57,097                                            
          Stock                                                                       
          Barrick Gold -–- ---   700  16,363                                          
          Fluor Corp.       --- ---   300  15,188                                     
          Glaxo Wellcome PLC --- ---   ---  20,813                                    
          Mutual Funds                                                                
          Latin America -–- -–-   ---  18,444                                         
          Mid-cap growth      -–-            -–-       -–-       45,953               
          U.S. Treasury  -–-                 -–-       -–-       43,926               
          Accrued int & div ---  ---   ---   4,066                                    
          Total Unattributed assets                              221,850              
          Total Assets                    2,245,138             2,579,739             
               The new assets held by the Thompson Partnership on the date of         
          decedent’s death could have derived from mutual funds contributed           
          to the partnership by Robert.  We are not persuaded that any of the         
          new assets derived from the assets contributed by decedent.  We             
          find, therefore, that assets totaling $1,450,745 held by the                
          Thompson Partnership at the date of decedent’s death are included           
          in the taxable estate under section 2036(a).                                
               The record establishes that George and Robert retained                 
          enjoyment and control over the property they contributed to the             
          partnership.  Decedent’s interests in the partnerships had no value         
          attributable to the property contributed by George and Robert to            
          the partnerships.  We find, therefore, that no additional value             
          attributable to the partnerships over the value of the property             
          included in decedent’s estate under section 2036(a) is included in          
          decedent’s taxable estate.                                                  






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