Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 50

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          include a separate value attributable to decedent’s lifetime                
          transfers of partnership interests. See Estate of Harper v.                 
          Commissioner, T.C. Memo. 2002-121.                                          
               E.   Conclusion                                                        
               The value of decedent’s interests in the partnerships as               
          reported on decedent’s estate tax return and as determined by               
          respondent in the notice of deficiency and the value of the assets          
          that we have found are to be included in the estate under section           
          2036(a) are as follows:                                                     


                                   Estate Tax    Notice of     Sec.                   
                                   Return       Deficiency        2036                
          Thompson Partnership      $837,691 $1,396,152       $1,450,745              
          Turner Partnership         875,811     1,717,977     1,489,091              
          Thompson Corp.               7,888        13,977            0               
          Turner Corp.                 5,190         4,094           0                
          Prior taxable gifts       19,324       166,167       0                      
          Total                    1,745,904     3,335,177     2,939,836              
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          

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