- 11 - Assurance Co. in the amount of $5,522,000, with an interest rate of 9.69 percent per annum (Provident Loan). The executors pledged decedent's class B shares to secure the Provident Loan. On October 3, 1990, respondent received the estate's timely filed return. Decedent's estate claimed a deduction of $289,079.77 for interest, accrued or paid though September 26, 1990, on the First Company Loan and the Provident Loan. On October 3, 1991, respondent also received a Form 843, Claim for Refund and Request for Abatement, in which decedent's estate claimed a refund for overpayment of estate tax resulting from administration expenses of $462,251.22, for interest expenses accrued or paid on the Provident Loan from September 26, 1990, though September 30, 1991. On January 15, 1991, decedent's estate received, in redemption of 24,100 class B shares, $1,590,600 in cash from the Company, which was used to pay principal and interest due on the Provident Loan on January 15, 1991, and income taxes arising out of the redemption of the class B shares. On September 16, 1991, decedent's estate borrowed $75,000 from the Company pursuant to a line of credit note (Second Company Loan). Thereafter, decedent's estate repaid the Second Company Loan together with accrued interest of $1,533.89. On December 30, 1991, the Company redeemed 69,994 shares of class B stock from decedent's estate, paying approximately $762,000 in cash and delivering a note in the amount ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011