- 48 - 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.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