- 33 -
decedent nor any of the GFLP partners executed any notes payable
to GFLP from December 1996 through December 1997.
After decedent died, Ms. Powell continued to use GFLP
account No. 7045 to pay some of decedent’s and Mr. Gore’s
personal expenses. In October 1997, checks in excess of $700
drawn on GFLP account No. 7045 and signed by Mr. Gore were issued
to pay property taxes on Mr. Gore’s California home. In December
1997, Ms. Powell wrote additional checks from GFLP account No.
7045 to pay expenses related to decedent’s home.
On December 8, 1997, Ms. Powell opened a money market
savings account on behalf of GFLP at Nations Bank, account No.
xx-xxxx-xx6020 (GFLP account No. 6020), with an initial deposit
of $5,000 from GFLP account No. 7045. On July 11, 2000, Ms.
Powell wrote a check for $192,800 from GFLP account No. 6020,
payable to the U.S. Treasury, for decedent’s Federal estate
taxes.31
The Estate and Gift Tax Returns
On March 15, 1998, decedent’s estate filed Form 709, U.S.
Gift (and Generation–Skipping Transfer) Tax Return (gift tax
return). Ms. Bowers prepared the gift tax return. The gift tax
return reported that decedent had made the following gifts on
January 8, 1997: (1) $102,500 cash to the Pamela Powell Trust;
31The record does not indicate the source of the funds on
deposit in GFLP account No. 6020, except for the $5,000
transferred from GFLP account No. 7045.
Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: November 10, 2007