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adjustments to tax resulting from omissions on the estate’s
Federal estate tax return.
10. 1991 and 1999 Cash Gifts
In 1991, decedent’s attorney recommended that decedent make
gifts to John Rector and Frederic Rector during the year in the
total amount of $595,000. Decedent followed this recommendation,
and she informed John Rector that she had made those gifts. On
January 6, 1999, decedent made separate cash gifts of $35,000 to
John Rector and Frederic Rector.
11. Federal Gift Tax Returns
Decedent filed a 1991 Federal gift tax return on October 30,
1992, reporting $595,000 in gifts to John Rector and Frederic
Rector. The return was prepared by an accountant in Nevada
County, California.
Decedent filed a 1999 Federal gift tax return on April 15,
2000, reporting gifts of 11.11-percent limited partner interests
to each of her sons. This return did not report decedent’s
$35,000 cash gifts to her sons.
12. Value of RLP Assets
The estate elected to value decedent’s gross estate as of
the alternate valuation date. On that date, the value of the
assets owned by RLP was $8,126,579.
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Last modified: March 27, 2008