Estate of Catherine E. Dowell, Deceased, Patricia Low, Executrix - Page 10

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          Sometime in August 1990 after her mother's death, Patricia Low              
          decided not to make payments to Sidney Dowell.  However, she                
          never told him that the remaining 75 percent of the agency stock            
          was his.  Patricia Low never told Jan Seigel, and he was unaware,           
          that she was not making the payments.                                       
               Neither Patricia Low nor Jan Seigel transferred decedent's             
          75 percent of the agency stock to Sidney Dowell.  Jan Seigel                
          prepared the New Jersey inheritance tax return for decedent's               
          estate.  The New Jersey inheritance tax return, which was signed            
          and filed by Patricia Low, shows her receiving, as beneficiary,             
          decedent's agency stock, less payments totaling $450,000 to be              
          made to her father.                                                         
               William Grinwis prepared the Federal estate tax return, in             
          part, from the information contained in the New Jersey                      
          inheritance tax return which was provided to him by Jan Seigel.             
          William Grinwis was given copies of the will and codicil when he            
          prepared the estate tax return in either late 1990 or early 1991.           
          The Federal estate tax return, which was signed and filed by                
          Patricia Low, deducts the $450,000 in projected payments as a               
          bequest to the surviving spouse.                                            
               Forms 1120S (U.S. Income Tax Returns for an S Corporation)             
          were filed for the agency for the years 1988 through 1993.  The             
          1990 through 1993 corporate tax returns were prepared by William            
          Grinwis and signed by Patricia Low as president.                            






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