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ESTATE OF TURNER v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 18911-08.

T.C. Memo. 2011-209

ESTATE OF CLYDE W. TURNER, SR., DECEASED, W. BARCLAY RUSHTON, EXECUTOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 30, 2011.

Attorney(s) appearing for the Case

Charles E. Hodges II , for petitioner.

Caroline R. Krivacka , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge.

Respondent determined a Federal estate tax deficiency of $659,912 with respect to the Estate of Clyde W. Turner, Sr. (estate). The primary issue for decision is whether the value of property Clyde W. Turner, Sr. (Clyde Sr.) transferred to Turner & Co., a family limited partnership, is included in his gross estate under section 2035, 2036, or 2038.1 We must also decide...

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