Estate of Joseph Cidulka, Deceased, James S. Bozik, Administrator - Page 2

                                                                                     
                               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 taxable              






Page:  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