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estate tax of $861,972, a prior payment of $875,000, and an
overpayment of $13,028.
Respondent commenced examinations of Mr. Stone’s estate tax
return and Ms. Stone’s estate tax return after July 22, 1998.
Mr. Stone’s estate and Ms. Stone’s estate cooperated with reason-
able requests by respondent for witnesses, information, docu-
ments, meetings, and interviews.
On September 7, 2001, respondent issued a notice of defi-
ciency (notice) to Mr. Stone’s estate. In that notice, respon-
dent determined, inter alia, to increase by $8,491,090 the value
attributable to Mr. Stone’s respective partnership interests in
ES3LP, ES4LP, CRSLP, RSMLP, and MSFLP reported in SCHEDULE F,
Other Miscellaneous Property Not Reportable Under Any Other
Schedule (Schedule F), of Mr. Stone’s estate tax return. In
support of that determination, respondent relied on seven alter-
native grounds, including the substance over form doctrine, the
economic substance doctrine, section 2036(a)(1) which was respon-
64(...continued)
Total
Partnership Liabilities
ES4LP $0
CRSLP 2,428,389
RSMLP 0
MSFLP 0
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