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and limited to the extent such fee has not
been claimed on Form 1041.
(E) By the amount of any interest paid by the
estate on the Federal Estate Tax deficiency and
not claimed on Form 1041.
(F) By an amount, not exceeding $12,021,
equal to any payment by the estate to the
estate of Marie Meriano in respect to the
claim by that estate against the decedent.
4. None of the items described in item (3) above
shall be allowed as a deduction for estate tax purposes
to the extent that the estate or any other party elects
to deduct such items for income tax purposes.
5. It is also hereby stipulated that the addition
to tax provided by Section 6653(b) of the Internal
Revenue Code shall be computed as an amount equal to
18.75% of the underpayment of tax, and not 50%.
6. It is hereby stipulated that the Pennsylvania
inheritance tax paid by the estate is $83,290.51.
On September 16, 1985, the Court ordered that the case be
stricken from the trial calendar in Philadelphia on September 30,
1985. In its order, the Court stated:
On September 3, 1985, the parties filed their
stipulation of disposition of issues in this case. As
indicated in that stipulation the final decision cannot
be entered in the case until final resolution of
certain matters now pending before the Court of Common
Pleas of Philadelphia County, Pennsylvania, Orphans'
Court Division, Administration No. 2259 of 1978, Estate
of Philip Meriano.
Subsequent to the Court's order of September 16, 1985,
petitioner's counsel, Latourette, filed eight status reports with
the Court8 informing the Court that the case had been settled and
8 The dates on which the status reports were filed are:
Nov. 28, 1986; Apr. 13, 1987; Oct. 1, 1987; Feb. 10, 1988; Sept.
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