Estate of Sylvia P. Goldman, Deceased, Marsha Goldberg and Linda Tanenbaum, Co-executrices - Page 7

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            2428    1/10/91   1/18/91     1/22/91  10,000         Andrew Goldberg Trust               
            2430  12/15/90    1/18/91     1/22/91  10,000         Andrew Goldberg Trust               
            2431    1/10/91     1/18/91   1/22/91  10,000         Richard Goldberg                    
            2432    1/10/91     1/18/91   1/22/91  10,000         Marsha Goldberg                     
            2433  12/15/90    1/18/91     1/22/91  10,000         Richard Goldberg                    
            2434  12/15/90    1/18/91     1/22/91  10,000         Marsha Goldberg                     
            2435  12/15/90    1/18/91     1/22/91  10,000         Caren Goldberg Trust                
            On January 29, 1991, Jay Tanenbaum deposited two $10,000 checks.                          
                  Decedent died on January 19, 1991.  Her will, which named                           
            Marsha and Linda as executrices, provided for specific bequests                           
            to Susan Tanenbaum, Steven Tanenbaum, Caren Goldberg, and Andrew                          
            Goldberg, each in the amount of $5,000.  All of decedent's                                
            personal effects and the residue of her estate were to be divided                         
            equally between Marsha and Linda.                                                         
                  On October 15, 1991, Marsha and Linda signed the estate's                           
            estate tax return, which was postmarked October 16, 1991.  They                           
            did not report the funds paid to recipients of the sixteen                                
            $10,000 checks and of the two $25,000 checks.  Neither Marsha nor                         
            Linda reviewed the return or scrutinized its accuracy.                                    
                  On July 11, 1994, respondent issued a notice determining an                         
            estate tax deficiency of $271,031.37.  This deficiency was                                
            attributable to respondent's determination that petitioner had                            
            failed to properly include in the gross estate the value of                               
            several assets, including the value of the funds paid to                                  
            recipients of the sixteen $10,000 checks and of the two $25,000                           
            checks.  Respondent also determined an accuracy-related penalty                           
            for negligence under section 6662(b)(1) in the amount of                                  
            $42,763.25.  Respondent determined that petitioner negligently                            
            failed to report six bank accounts with an aggregate value of                             





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