- 7 - 2428 1/10/91 1/18/91 1/22/91 10,000 Andrew Goldberg Trust 2430 12/15/90 1/18/91 1/22/91 10,000 Andrew Goldberg Trust 2431 1/10/91 1/18/91 1/22/91 10,000 Richard Goldberg 2432 1/10/91 1/18/91 1/22/91 10,000 Marsha Goldberg 2433 12/15/90 1/18/91 1/22/91 10,000 Richard Goldberg 2434 12/15/90 1/18/91 1/22/91 10,000 Marsha Goldberg 2435 12/15/90 1/18/91 1/22/91 10,000 Caren Goldberg Trust On January 29, 1991, Jay Tanenbaum deposited two $10,000 checks. Decedent died on January 19, 1991. Her will, which named Marsha and Linda as executrices, provided for specific bequests to Susan Tanenbaum, Steven Tanenbaum, Caren Goldberg, and Andrew Goldberg, each in the amount of $5,000. All of decedent's personal effects and the residue of her estate were to be divided equally between Marsha and Linda. On October 15, 1991, Marsha and Linda signed the estate's estate tax return, which was postmarked October 16, 1991. They did not report the funds paid to recipients of the sixteen $10,000 checks and of the two $25,000 checks. Neither Marsha nor Linda reviewed the return or scrutinized its accuracy. On July 11, 1994, respondent issued a notice determining an estate tax deficiency of $271,031.37. This deficiency was attributable to respondent's determination that petitioner had failed to properly include in the gross estate the value of several assets, including the value of the funds paid to recipients of the sixteen $10,000 checks and of the two $25,000 checks. Respondent also determined an accuracy-related penalty for negligence under section 6662(b)(1) in the amount of $42,763.25. Respondent determined that petitioner negligently failed to report six bank accounts with an aggregate value ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011