- 4 -
and additions thereto totaling more than $1 million. Respondent
assessed these deficiencies on July 28, 1995. To date, Executor
has not made any payments with respect thereto.
The Stipulation states as follows:
THE PARTIES hereby stipulate and agree that:
1. They have agreed to resolve the above-entitled
case on the basis that the works of art created by the
decedent and unsold on the date of her death were not
transferred by the decedent to Sculptotek, Inc. during
her lifetime and are therefore includible in her gross
estate.
2. The gross estate is $12,123,455.73.
3. The total amount of adjusted taxable gifts is
$2,856,317.00.
4. (a) The administration expenses claimed on
petitioner’s Form 706, as adjusted by the statutory
notice of deficiency issued by respondent, will be
allowable as deductible expenses.
(b) Additional administration expenses,
including statutory executor’s commissions under New
York law and reasonable legal fees, also will be
allowable as deductible expenses to the extent such
expenses are properly claimed as administrative
expenses and are substantiated.
5. (a) The amount of federal gift tax,
including interest and penalties, that the parties have
agreed is due in the related proceeding bearing docket
no. 27393-93 will be allowed as deductions to the
extent such tax, interest, and penalties are paid.
(b) The amount of related New York gift tax,
including interest and penalties, also will be allowed
as deductions to the extent such tax, interest, and
penalties are paid.
6. New York State death taxes in the amount of
$312,200.51 or such amount necessary to secure the
maximum credit allowable will be allowed as a credit to
the extent such taxes are paid.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011