- 11 - IV. The Estate Tax Return The estate filed Form 706, U.S. Estate (and Generation- Skipping Transfer) Tax Return, on September 7, 1999. The estate reported the residence, the vacant lot, a checking account, personal property, a 1-percent general partnership interest in Crane Properties, and a 2-percent general partnership interest in KPLP as owned directly by Austin at his death. The estate also claimed deductions for funeral expenses and debts of the decedent, adjusted taxable gifts of $600,030 for the 1995 gifts of KPLP and Crane Properties interests, gross estate tax of $222,118 subject to the maximum unified credit against estate tax of $202,050, and tax due of $20,068. On August 29, 2002, respondent issued a notice of deficiency addressed to the estate and the living trust. On the same day, respondent issued a notice of deficiency to the living trust as transferee of the estate’s liabilities (the notices). In the notices, respondent determined that the full values of the assets held by KPLP were includable in the gross estate under sections 2036 and 2038. Respondent also determined that the values of the assets held by the living trust were includable in the gross estate under sections 2036 and 2038. Respondent also reduced the estate’s adjusted taxable gifts from $600,030 to $121,798, reflecting in part respondent’s exclusion of the 1995 gifts ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011