- 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