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partnership units (14,504) and applying a 31-percent discount for
lack of marketability. No distinction was made in the appraisals
or on those returns between the limited partnership units given
to decedent’s children and the income rights given to decedent’s
grandchildren in the units retained by decedent’s trust.
Mr. Bigelow reported on the 1994 gift tax return that
decedent had made cash gifts of $10,000 to Mr. Bigelow and
$10,000 to his wife, forgiven Mr. Bigelow $150,000 of
indebtedness evidenced by a promissory note, and assigned
interests in a promissory note payable to decedent by Mr. Bigelow
to Franklin T. Bigelow III and Anna D. Bigelow, $5,000 each. He
also reported on the 1995-97 gift tax returns combined cash gifts
to Mr. Bigelow and his wife of $7,350 in 1995, $7,500 in 1996,
and $22,000 in 1997.
b. The Estate Tax Return
On the estate tax return, Mr. Bigelow reported a gross
estate of $175,957.57 and taxable gifts of $463,070.
The amount reported as the gross estate included $10,000 of
personal property, the refund of a $2,460 deposit owed to
decedent by the assisted-living facility, and $163,497.57 of
transfers during decedent’s life. The amount reported as
transfers during decedent’s life included $135,079.88 for
decedent’s limited partnership in Spindrift; $19,912.50 for her
general partnership interest in Spindrift; $5,416.83 held by
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