- 32 - 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 DeductionPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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