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MSFLP and certain other property to be held by the AWS Trust
pursuant to Mr. Stone’s will. In Mr. Stone’s estate tax return,
the co-personal representatives55 of Mr. Stone’s estate made a
qualified terminable interest property (QTIP) election under
section 2056(b)(7) with respect to the AWS Trust. Consequently,
although the claimed respective date-of-death values of Mr.
Stone’s partnership interests in ES3LP and certain other property
to be held by that trust were reported in Mr. Stone’s estate tax
return as part of Mr. Stone’s estate, Mr. Stone’s estate claimed
a deduction in that return under section 2056(a) for such respec-
tive values of such partnership interests and such certain other
property. Mr. Stone’s estate tax return showed net estate tax of
$4,031,260, prior payments of $1,698,074, and a balance due of
$2,333,186.
On March 10, 1999, the IRS received $2,524,858.57 (March 10,
1999 payment) in payment of the estate tax shown due (i.e.,
$2,333,186) in Mr. Stone’s estate tax return and interest.56 Of
that total amount of estate tax and interest paid in 1999, ES4LP
paid $371,336.72, CRSLP paid $1,000,641.91, RSMLP paid
$571,597.34, and MSFLP paid $514,194.67. In 1999, State estate
55All of the children are co-personal representatives of Mr.
Stone’s estate.
56The March 10, 1999 payment included interest because Mr.
Stone’s estate applied for and received an extension of time
within which to pay the balance of the estate tax due with
respect to Mr. Stone’s estate.
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