Estate of Philip Meriano, Deceased, Anita Panepinto, Administratrix - Page 32

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                    The Respondent argues that such amount would be                   
               deductible if the Petitioner furnishes substantiation                  
               that the amount claimed has been paid or will be paid,                 
               and has not been claimed on Form 1041.  Such                           
               substantiation may be provided by the use of Form 4421.                
                    6. Addition to Tax Under Code Section 6653(b)                     
                    In the Stipulation of Disposition of Issues filed                 
               with this Court in 1985, the parties agreed, and                       
               continue to agree, 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.                                                   
          The taxable estate as tentatively agreed in The First                       
          Stipulation was $1,988,288.12.  The taxable estate as tentatively           
          agreed in The Second Stipulation is $1,328,614.69. The decrease             
          results from (1) an increase in Schedule J of $647,652.44 which             
          approximates the sum of $401,256.10, the amount of fees allowed             
          to Lynch and Reardon by the Orphans' Court, and the Dilworth                
          firm's legal fees of $231,34.50 referred to in paragraph 2(C) of            
          The First Stipulation, and (2) an increase in Schedule K of                 
          $12,021, which is the amount referred to in paragraph 2(E) in The           
          First Stipulation.                                                          
               This case was tried for 11-1/2 hours from December 5, 1994,            
          through December 7, 1994.                                                   
                                       OPINION                                        
          Issue 1. Claimed Theft Loss Deduction                                       










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