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GFLP of $1,919,982.34 Ms. Bowers then applied an additional
discount in calculating the value of decedent’s alleged gifts of
limited partnership interests to her children reported on Form
709.
On October 19, 1998, the estate filed Form 706. Ms. Bowers
prepared the Form 706, which reported a gross estate of
$1,776,893, deductions of $395,446, and a taxable estate of
$1,381,447. The Form 706 reported that decedent owned a “one-
third interest” in GFLP, that the partnership interest had a book
value of $1,424,908,35 and that the partnership interest had a
fair market value, of $740,036.36 On Schedule C, Mortgages,
Notes, and Cash, of Form 706, the estate listed a $46,664 note
payable to decedent from GFLP as an asset of the estate. On
Schedule K, Debts of the Decedent, and Mortgages and Liens, of
34Mr. Sallee stated in his opinion letter that interests in
GFLP were held as follows: Ms. Powell and Mr. Gore each held a
1-percent general partnership interest, decedent held a 34-
percent limited partnership interest, and the Pamela Powell and
Michael Gore Trusts each held a 32-percent limited partnership
interest. However, Mr. Sallee’s description of decedent’s
limited partnership interest was incorrect; decedent held a
32.667-percent limited partnership interest.
35In preparing the tax return, Ms. Bowers described
decedent’s limited partnership interest as a “one-third
interest”, rather than a 32.667-percent interest.
36In calculating the value of decedent’s limited partnership
interest in GFLP, Ms. Bowers adjusted the total fair market value
of GFLP stated in the valuation opinion because Mr. Sallee had
based his opinion on the asset values reported on Sidney Gore’s
estate tax return.
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Last modified: November 10, 2007