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.
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