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$740,036, the discounted value of decedent’s limited partnership
interest in GFLP reported on the estate tax return.
Alternatively, respondent disallowed the discount for lack of
control and marketability that was applied in valuing decedent’s
limited partnership interest for estate tax purposes and
increased the taxable estate by the difference between the
undiscounted fair market value of that partnership interest
($1,665,760) and the discounted value reported on the estate tax
return ($740,036).
In conjunction with respondent’s alternative position and
the gift tax deficiency determined separately, respondent
increased the value of the gross estate by the amount of
additional gift tax due on the undiscounted fair market values of
the limited partnership interests decedent allegedly gave to the
Pamela Powell and Michael Gore Trusts and allowed those amounts
as deductions. Under either alternative, respondent included
$102,139, representing the value of the Smith Barney account, in
the gross estate under section 2033 and disallowed the estate’s
deduction of $1,543 for ad valorem tax on decedent’s home.38
38Respondent’s computation of the estate tax deficiency
erroneously omits the additional tax owed as a result of the
disallowed deduction of $1,543 for real estate taxes.
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Last modified: November 10, 2007