Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor - Page 2

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          concessions by the parties, the issues for decision are:                    
          (1) Whether an entity entitled “The Lea K. Hillgren Partnership,            
          A California Limited Partnership” (LKHP or partnership) is a                
          partnership that should be disregarded under section 2036(a) in             
          valuing seven properties in which decedent had an interest;                 
          (2) the effect of a Business Loan Agreement (BLA) between                   
          decedent and her brother on the value of four properties in which           
          decedent had an interest.  Respondent concedes that the estate is           
          not liable for the accuracy-related penalty under section 6662.             
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect as of the date of decedent’s            
          death, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  Lea K.           
          Hillgren (decedent) was a resident of California at the time of             
          her death.  The executor of decedent’s estate, her brother, Mark            
          Hillgren (Hillgren), resided in California when the petition in             
          this case was filed.                                                        
          Decedent’s Background                                                       
               Decedent graduated from California State University with a             
          degree in restaurant and hotel management.  She was a restaurant            
          manager for Hamburger Hamlet, attended cooking school in France,            

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