ESTATE OF REICHARDT v. COMMISSIONER

Docket No. 1224-98.

114 T.C. 144 (2000)

ESTATE OF CHARLES E. REICHARDT, DECEASED, WILLIAM D. REICHARDT, INDEPENDENT EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 1, 2000.


Attorney(s) appearing for the Case

Rex B. Cruse, Jr., and S. Jeffrey Gately, for petitioner.

Deborah H. Delgado, T. Richard Sealy III, and James G. MacDonald, for respondent.


COLVIN, Judge:

Respondent determined that petitioner is liable for a deficiency in gift tax of $161,494 for gifts made by decedent in 1993 and a deficiency in estate tax of $358,771. After concessions,1 the issue for decision is whether assets that decedent transferred to the partnership are included in his gross estate under section 2036(a). We hold that they are, and that the fair market value of those assets was $1,634,654 when...

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