- 36 - Form 706, the estate deducted $1,543 for real estate taxes owed on decedent’s home. Respondent’s Determinations On September 26, 2001, respondent issued a notice of deficiency with respect to the gift tax return, in which he advanced two alternative positions. Respondent determined that the transfer of the Marital Fund assets was an indirect gift of one-third of the assets to Ms. Powell and one-third of the assets to Mr. Gore. Respondent valued each indirect gift at $1,479,514, the fair market value of one-third of the Marital Fund assets. Alternatively, respondent disallowed the discount that was applied in valuing the partnership interests transferred to the Pamela Powell and Michael Gore Trusts and valued each gift at its fair market value, which respondent determined to be $1,479,514, rather than $503,834 as shown on the gift tax return. Respondent also included a gift of $1,700 cash to Ms. Powell and a gift of $870 cash to Mr. Gore.37 On September 26, 2001, respondent issued a separate notice of deficiency with respect to the estate tax return, in which he advanced two alternative positions. Respondent included the fair market value of GFLP ($4,977,280) in decedent’s taxable estate under sections 2036 and/or 2038 and reduced the taxable estate by 37Petitioner has not contested respondent’s determination to increase decedent’s taxable gifts by $1,700 and $870, and these amounts are not at issue in this case.Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 NextLast modified: November 10, 2007