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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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