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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 of
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Last modified: May 25, 2011