- 24 - KPLP’s assets were contributed as follows: Edna Austin Korby sons Living trust Total 38.26 58.46 1.28 2.00 100.00 The parties agree that if section 2036 applies to the assets contributed to KPLP by Austin and Edna, 38.26 percent of KPLP’s value should be included in Edna’s gross estate and 58.46 percent of KPLP’s value should be included in Austin’s gross estate.8 In calculating the values of the KPLP assets at Edna’s death, the parties shall take into consideration their stipulation that the value of Amoco stock at Edna’s death was $43.039 per share, not $89.13 per share as stated in the notice of deficiency. II. The 1995 and 1998 Annuities The estate argues that respondent incorrectly included the 1995 annuity, valued at $143,000 at Edna’s death, in the KPLP assets. The estate does not object to respondent’s valuation of the annuity. The annuity entitled Austin to payments after the annuity date for a 10-year period as long as he was living. If Austin died during the 10-year period, the payments would continue to his beneficiaries. Austin’s sons were named as 8This 38.26-percent portion of KPLP’s value is includable in Edna’s gross estate in addition to the 2-percent KPLP general partnership interest held by the living trust, which the estate does not dispute is included in Edna’s gross estate under sec. 2036(a) as living trust property. In addition, the calculation of the portion includable in each gross estate takes into account that the 1.28-percent interest contributed by the Korby sons is not included in either Austin’s or Edna’s gross estate.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011