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
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Last modified: May 25, 2011