Estate of Sylvia P. Goldman, Deceased, Marsha Goldberg and Linda Tanenbaum, Co-executrices - Page 2

               1.  Whether the value of funds (i.e., $160,000), paid to               
          recipients of sixteen $10,000 checks drawn on the decedent's                
          checking account by her attorney-in-fact, is includable in the              
          gross estate.  We hold that it is includable.                               
               2.  Whether the value of funds (i.e., $50,000), paid to                
          recipients of two $25,000 checks drawn on the decedent's checking           
          account by her attorney-in-fact, is includable in the gross                 
          estate.  We hold that it is includable.                                     
               3.  Whether petitioner is liable for an accuracy-related               
          penalty for negligence in the amount of $42,763.25.  We hold that           
          petitioner is liable.                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The Stipulation of Settled Issues and the Stipulation of Facts              
          are incorporated by this reference.  All section references are             
          to the Internal Revenue Code in effect as of the date of                    
          decedent's death, and all Rule references are to the Tax Court              
          Rules of Practice and Procedure, unless otherwise indicated.                
              The estate (petitioner) had a mailing address, and the co-             
          executrices resided, in New York, New York, at the time the                 
          petition was filed.                                                         
               Sylvia Goldman (decedent) resided in New York, New York, in            
          the years prior to her death in 1991.  Decedent had two children,           
          Marsha Goldberg and Linda Tanenbaum.  Marsha was married to                 
          Richard Goldberg, and Linda was married to Jay Tanenbaum.                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011