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(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.
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Last modified: November 10, 2007