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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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Last modified: May 25, 2011