1. Whether the value of funds (i.e., $160,000), paid to recipients of sixteen $10,000 checks drawn on the decedent's checking account by her attorney-in-fact, is includable in the gross estate. We hold that it is includable. 2. Whether the value of funds (i.e., $50,000), paid to recipients of two $25,000 checks drawn on the decedent's checking account by her attorney-in-fact, is includable in the gross estate. We hold that it is includable. 3. Whether petitioner is liable for an accuracy-related penalty for negligence in the amount of $42,763.25. We hold that petitioner is liable. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The Stipulation of Settled Issues and the Stipulation of Facts are incorporated by this reference. All section references are to the Internal Revenue Code in effect as of the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. The estate (petitioner) had a mailing address, and the co- executrices resided, in New York, New York, at the time the petition was filed. Sylvia Goldman (decedent) resided in New York, New York, in the years prior to her death in 1991. Decedent had two children, Marsha Goldberg and Linda Tanenbaum. Marsha was married to Richard Goldberg, and Linda was married to Jay Tanenbaum.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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