- 5 - subsequent to the issuance of the statutory notice of deficiency. c. With respect to the issues of the disallowed claim against the estate in the amount of $500,000.00, respondent concedes petitioner is entitled to an adjustment of $500,000.00 reducing the amount of the gross estate reported on petitioner's estate tax return. This adjustment is in lieu of the claim against the estate in the amount of $500,000.00. d. With respect to the increase in adjusted taxable gifts in the total amount of $21,578.00, the petitioner concedes the issue in full, as reflected in petitioner's amended return filed subsequent to the issuance of the statutory notice of deficiency. 4. In addition, the parties agree that petitioner is entitled to deductions for additional expenses incurred in administering the property of the estate which expenses were incurred subsequent to the filing of the estate tax return. These deductions will be allowed as verified. The parties agree to this STIPULATION OF SETTLEMENT. Based on the stipulation of settlement, the Court allowed the parties time to exchange information regarding additional administrative expenses, to compute the correct amount of estate tax due, and to prepare decision documents. After reviewing the agreed upon fair market value for the Ranch, petitioner's counsel advised respondent that Executrix intended to pursue its protective election under section 20.2032A-8(b), Estate Tax Regs. Consequently, on August 26, 1995, Executrix mailed respondent an amended Federal estate tax return in which she made an election under section 2032A for the Ranch.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011