- 96 - 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 0Page: Previous 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 Next
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