Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 37




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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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