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of her gross estate the date-of-death values claimed for all the
assets held by the AWS Trust as of October 16, 1998, the date of
Ms. Stone’s death (i.e., the claimed fair market value on that
date of the 69.973 limited partnership interest in ES3LP, the
claimed fair market value on that date of all the assets in Mr.
Stone’s retirement account on that date, and the claimed present
value on that date of the deferred compensation from Stone Manu-
facturing that remained to be paid as of that date).
Ms. Stone’s estate tax return also reported as part of the
value of her gross estate the claimed value as of the date of Ms.
Stone’s death of her limited partnership interest in each of the
Five Partnerships.64 Ms. Stone’s estate tax return showed net
64E&Y was retained to provide opinions on the fair market
value on the date of Ms. Stone’s death of her limited partnership
interest in each of ES4LP, CRSLP, RSMLP, and MSFLP. E&Y based
those opinions on, inter alia, the assumptions that, as of the
date of Ms. Stone’s death, ES4LP, CRSLP, RSMLP, and MSFLP had the
following respective liabilities for “an estate tax payable” with
respect to Mr. Stone’s estate:
Erroneous Assumptions Relied on by
Partnership E&Y Regarding Estate Tax Liability
ES4LP $469,882
CRSLP 1,269,116
RSMLP 723,468
MSFLP 650,899
The parties agree that neither the Federal estate tax nor the
State estate tax with respect to Mr. Stone’s estate was a liabil-
ity of ES4LP, CRSLP, RSMLP, or MSFLP and that, as of Oct. 16,
1998, ES4LP, CRSLP, RSMLP, and MSFLP had the following total
liabilities:
(continued...)
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