- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011