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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.
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