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ESTATE OF STONE v. COMMISSIONER OF INTERNAL REVENUE

No. 23290-09.

T.C. Memo. 2012-48

ESTATE OF JOANNE HARRISON STONE, DECEASED, COSBY A. STONE AND MICHAEL D. STONE, PERSONAL REPRESENTATIVES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 22, 2012.

Attorney(s) appearing for the Case

Dudley W. Taylor , for petitioner.

Caroline R. Krivacka , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge.

Respondent determined a $2,563,290 Federal estate tax deficiency against the Estate of Joanne Stone (estate). After settlement of certain issues, the sole issue remaining for decision is whether the value of real property transferred by Joanne Stone (decedent) to a family limited partnership should be included in the value of her gross estate pursuant to section 2036(a).

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