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Additions to Tax
Deficiency Sec. 6653(a)(1) Sec. 6651(a)(1)
$359,822 $17,991 $89,956
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect as of the date of the decedent's
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The issues for decision are as follows:
1. Whether the notice of deficiency was issued prior to the
expiration of the 3-year limitations period provided for in
section 6501(a). We hold that the notice was issued in a timely
manner.
2. Whether petitioner, pursuant to section 2040, is
entitled to exclude from the gross estate $158,942 of joint
tenancy property. We hold that petitioner is not so entitled.
3. Whether petitioner, pursuant to section 2053(a)(3), is
entitled to deduct from the gross estate $363,458 and $306,563
relating to two promissory notes. We hold that petitioner is not
so entitled.
4. Whether petitioner, pursuant to section 2054, is
entitled to deduct from the gross estate $300,000 as a theft
loss. We hold that petitioner is so entitled.
5. Whether petitioner, pursuant to section 6653(a)(1), is
liable for an addition to tax for negligence. We hold that
petitioner is liable.
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Last modified: May 25, 2011