- 49 - Further, decedent’s stock in Turner Corp. and Thompson Corp. had no value apart from the corporations’ interests in the partnerships. The value of decedent’s stock in the corporations is included in the value of the assets included in his estate under section 2036(a). We find, therefore, that no additional value attributable to such stock is included in computing decedent’s taxable estate. D. Adjusted Taxable Gifts Decedent’s estate’s estate tax return included, as part of the gross estate, $19,324 as “adjusted taxable gifts” pursuant to section 2001(b) for lifetime transfers of decedent’s interest in the partnerships. Respondent’s notice of deficiency proposed to increase this amount to $166,167. Neither party addresses the impact of the application of section 2036(a) on the value of the prior gifts of partnership interests. We have found that pursuant to section 2036(a) decedent’s taxable estate includes the full value as of decedent’s death of assets transferred by him to the partnerships and held by the partnerships at decedent’s death. We have also found that decedent’s interests in the partnerships had no value apart from the assets he contributed to the partnerships because Betsy and Robert maintained control over the property they transferred to their respective partnerships. Therefore, we hold that in computing the proper estate tax due, it is not appropriate toPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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