- 2 -
except for the fair market value of an interest in a closely held
corporation that was included in decedent’s estate as part of a
family limited partnership.2
FINDINGS OF FACT
Helen A. Deputy (decedent) died on September 15, 1997, when
her legal residence was in Elkhart, Indiana. William J. Deputy
and Robert J. Deputy were appointed coexecutors of decedent’s
estate. William J. Deputy, as coexecutor of the estate, filed
timely petitions with respect to respondent’s determination of
separate estate and gift tax deficiencies. At the time the
petitions were filed, William J. Deputy resided in New Buffalo,
Michigan, and Robert J. Deputy resided in Elkhart, Indiana.
Decedent was married to Sherrill S. Deputy. They had six
sons, including William J. Deputy and Robert J. Deputy, the
coexecutors of decedent’s estate. On December 12, 1996, decedent
formed a family limited partnership (Deputy FLP), retaining a 99-
percent limited partnership interest and creating two 0.5-
percent general partnership interests, one held by decedent and
2 These cases involve the fair market value of interests in
a closely held corporation transferred by gift during 1997 and
another interest held by decedent through a family limited
partnership at the time of her death, Sept. 15, 1997. The
transferred interests were substantially smaller than the
interest held by decedent. The parties have stipulated that the
Court’s decision with respect to the fair market value on Sept.
15, 1997, will bind them with respect to the 1997 gift tax
values. Accordingly, we consider only the fair market value on
Sept. 15, 1997.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011