- 3 -
incurred by her son, Rodney B. Amlie (Rod), constituted a gift;
and
(4) whether the estate is liable for an accuracy-related
penalty of $51,571 under section 6662(a) for underpayment of
estate tax attributable to understatement of the value of
decedent's FABG stock.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts and the
accompanying exhibits.
Decedent was a U.S. citizen domiciled in Fort Dodge, Iowa,
when she died testate on October 18, 1998. Rod was appointed
executor of the estate and continues to function in that
capacity. At the time of filing the petition, Rod resided in
Humboldt, Iowa.
Introduction
Decedent executed her last will and testament in November
1978. The will included a specific bequest of decedent's farm
land to her daughter, Rosemary Ahlerich, and her son, Thomas,4 in
equal shares. The will also included a specific bequest to Rod
of a portion of certain bank stock, discussed infra, that
decedent held at the time her will was executed. The portion
4 As Thomas predeceased decedent, his interest passed to his
two children, Susan Wendel and Thomas Robert Amlie.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011