- 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.
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