- 11 - 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 assetsPage: 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