- 37 - $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.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: November 10, 2007