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$69,000 to Ms. Fraser).53
Financial statements for MSFLP for 1998 (MSFLP’s 1998 finan-
cial statements) reflected as an expense $585,23954 of “Estate
Taxes”.
On September 15, 1998, Mr. Stone’s estate filed Form 706,
United States Estate (and Generation-Skipping Transfer) Tax
Return (Mr. Stone’s estate tax return). Mr. Stone’s estate tax
return reported as part of the value of Mr. Stone’s gross estate,
inter alia, date-of-death values claimed for Mr. Stone’s respec-
tive partnership interests in ES3LP, ES4LP, CRSLP, RSMLP, and
52(...continued)
that E&Y’s Estate tax allocation schedule reflected as payable by
MSFLP in 1998.
53The only other distribution reflected in MSFLP’s partner-
ship return for 1998 was because of Ms. Stone’s death in that
year. The partnership return that MSFLP filed for 1998 reflected
that MSFLP opened a capital account for Ms. Stone’s estate (Ms.
Stone’s estate’s capital account in MSFLP), and the balance in
Ms. Stone’s capital account as a limited partner was transferred
to Ms. Stone’s estate’s capital account in MSFLP.
Because of Mr. Stone’s death in 1997, in that year, as
reflected in the partnership return that MSFLP filed for 1997,
MSFLP opened capital accounts for his estate (Mr. Stone’s es-
tate’s capital accounts in MSFLP), and the balances in Mr.
Stone’s capital accounts in MSFLP as a general partner and a
limited partner were transferred to Mr. Stone’s estate’s capital
accounts in MSFLP. The partnership return that MSFLP filed for
1997 showed that MSFLP did not make distributions during that
year to any of its other partners.
54The $585,239 expense reflected in MSFLP’s 1998 financial
statements equals the total amount of Federal and State estate
taxes with respect to Mr. Stone’s estate that E&Y’s estate tax
allocation schedule reflected as payable by MSFLP in 1998. See
supra note 52.
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