Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 49




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               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 to               






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