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lists decedent's correct Social Security number and date of
death.
The notice of deficiency includes an explanation of
adjustments which states:
(a) The decedent and her spouse filed Federal Gift Tax
Returns for the period ending December 31, 1990, and elected
to split the gifts made by each to third parties. The gift
tax returns did not correctly reflect this election. The
adjusted taxable gift of the decedent is determined to be
$85,711.00, rather than zero as reported at Line 4 of Page 1
of the Federal Estate Tax Return. Exhibits A and B of this
notice indicate how the gift tax returns should have been
filed. The corrections to the gift tax returns include the
determination that all gifts by both donors must be split
and that the gifts reported by the decedent's spouse were
overstated because a portion of the spouse's gifts were
incomplete and should not have been reported. See Item (i)
of this notice for a related adjustment.
Accordingly, the taxable estate is increased $85,711.00.
(b) On the controlling valuation date (date of decedent's
death) the fair market value of the real property identified
at Item 1 of Schedule A of the Federal Estate Tax Return was
$74,500, rather than $59,500.00 as reported.
Accordingly, the taxable estate is increased $15,000.
(c) On the controlling valuation date the fair market value
of the real property identified at Item 3 of Schedule A was
$61,000, rather than $47,000.00 as reported.
Accordingly, the taxable estate is increased $14,000.
(d) On the controlling valuation date the fair market value
of the real property identified at Item 4 of Schedule A was
$311,580, rather than $250,000.00 as reported.
Accordingly, the taxable estate is increased $61,580.00.
(e) On the controlling valuation date the fair market value
of the real property identified at Item 5 of Schedule A was
$16,430, rather than $17,520.00 as reported.
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Last modified: May 25, 2011