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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.
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Last modified: November 10, 2007