Additions to tax Tax year ended Deficiency Sec. 6653(a)(1) Sec.6653(a)(2) Sec.6651(a)(1) Dec. 31, 1982 $845,678 $42,283.90 50% of the $211,419.50 interest due on $845,678 All section references are to the Internal Revenue Code as in effect at the time of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. A number of adjustments were made by respondent in the estate tax notice of deficiency, all of which have been disposed of by agreement of the parties, except those involving the proper valuation of gifts made by decedent in the years 1980, 1981, and 1982 of stock in State Outdoor Advertising, Inc. (SOAI), which respondent determined to be included in the taxable estate on which the tentative estate tax is computed. Decedent filed no gift tax return for any of the years 1980, 1981, or 1982. The notice of deficiency for gift taxes is with respect to the year 1982 only but incorporates the amount of gifts for prior periods. It shows the amount of 1982 taxable gifts as $2,162,620, less a $10,000 annual exclusion, or a net of $2,152,620. The notice of deficiency for gift tax for 1982 shows "Total Amount of Taxable Gifts for Prior Periods" as $95,789, whereas the notice of deficiency for estate tax shows adjusted taxablePage: 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