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Eugene Earle Stone, III (Mr. Stone’s estate), and the Estate of
Allene W. Stone (Ms. Stone’s estate) in the amounts of $3,268,401
and $741,809, respectively. The only issue remaining for deci-
sion in the case of Mr. Stone’s estate is whether certain assets
owned by each of five family limited partnerships (Five Partner-
ships) are includible in his gross estate under section
2036(a)(1).1 We hold that none of the assets owned by any of
the Five Partnerships is includible in Mr. Stone’s gross estate
under section 2036(a)(1). There are two issues remaining for
decision in the case of Ms. Stone’s estate. The first issue is
whether certain assets owned by each of the Five Partnerships are
includible in her gross estate under section 2036(a)(1). We hold
that none of the assets owned by any of the Five Partnerships is
includible in Ms. Stone’s gross estate under section 2036(a)(1).
The second issue is whether certain assets owned by one of the
Five Partnerships is includible in Ms. Stone’s gross estate under
section 2044. We hold that none of the assets owned by that
partnership is includible in Ms. Stone’s gross estate under
section 2044.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect on the respective dates of
the deaths of Eugene Earle Stone, III (Mr. Stone), and Allene W.
Stone (Ms. Stone). All Rule references are to the Tax Court
Rules of Practice and Procedure.
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