- 4 - (1) Whether the values of the assets of the Sidney Gore Marital Fund (Marital Fund assets) are includable in Sylvia Gore’s (decedent’s) gross estate under section 2033 or section 2041; (2) alternatively, if decedent completed a transfer of Marital Fund assets to the Gore Family Limited Partnership (GFLP) before her death, whether the values of those assets are includable in decedent’s gross estate under sections 2041, 2036, and/or 2038; (3) alternatively, if the value of the property to be included in decedent’s estate is that of a 32.667-percent limited partnership interest in GFLP, whether the value of that interest on June 12, 1997, was $1,260,472, as respondent contends, or $740,036, the value reported on the estate’s Federal estate tax return; (4) if the values of the Marital Fund assets are includable in decedent’s gross estate under sections 2033, 2036, 2038, 3(...continued) State death tax, if it is paid and claimed by the estate within the period specified in sec. 2011(c)(1). (2) Petitioner also raised the issue of whether respondent erred in not applying a $192,800 Federal estate tax payment made on July 14, 2000, to reduce the amount of the estate tax deficiency respondent determined in the notice of deficiency dated Sept. 26, 2001. Respondent represents that the estate’s unassessed prepayment of estate tax has been credited to the estate’s account and will be treated as a July 14, 2000, payment in computing any outstanding estate tax liability as a result of this opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007