Estate of Austin Korby - Page 11

                                       - 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 of              







Page:  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