- 94 - on that date in Mr. Stone’s retirement account, and the right on that date to Mr. Stone’s deferred compensation from Stone Manu- facturing. The respective identities and values of the assets owned by ES3LP on the date of Mr. Stone’s death on June 5, 1997, were not the same as the respective identities and values of the assets owned by that partnership on the date of Ms. Stone’s death on October 16, 1998. Moreover, the respective identities and values of the assets in Mr. Stone’s retirement account on the date of Mr. Stone’s death on June 5, 1997, were not the same as the respective identities and values of the assets in that re- tirement account on the date of Ms. Stone’s death on October 16, 1998. In addition, the present value on the date of Ms. Stone’s death of Mr. Stone’s right to deferred compensation from Stone Manufacturing was less than the present value of his right to such compensation on the date of his death. On July 20, 1999, the IRS received $875,000 (July 20, 1999 payment) in payment of the anticipated estate tax with respect to Ms. Stone’s estate. On January 20, 2000, Ms. Stone’s estate filed an estate tax return (Ms. Stone’s estate tax return). Pursuant to section 2044, Ms. Stone’s estate tax return reported as part of the value 63(...continued) Stone’s death Mr. Stone’s general partnership interest in ES3LP was converted pursuant to the partnership agreement of ES3LP into a limited partnership interest.Page: Previous 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 Next
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