Estate of Edna Korby - Page 11

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          unified credit amount in effect for the year of death, was to be            
          transferred to the marital deduction trust.  The remaining assets           
          were to be transferred to the family trust.                                 
          IV. The Estate Tax Return                                                   
               The estate mailed Form 706, U.S. Estate (and Generation-               
          Skipping Transfer) Tax Return, on September 1, 1999, and it was             
          received by the IRS on September 5, 1999.  The estate tax return            
          listed as jointly owned property the residence, the vacant lot,             
          and a checking account, including half their total value as part            
          of the gross estate.  It listed as miscellaneous property half              
          the Korbys’ general partnership interests in Crane Properties and           
          KPLP, and personal property.  The total gross estate value was              
          listed as $73,398.  The estate claimed a deduction for funeral              
          expenses and claimed the marital deduction in an amount                     
          approximately equal to the value of the jointly owned property in           
          the gross estate.  The estate also reported adjusted taxable                
          gifts of $600,030 for the 1995 gifts of KPLP and Crane Properties           
          interests, gross estate tax of $202,050 subject to the unified              
          credit against estate tax, and zero tax due.                                
               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           






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