Estate of Louise Nevelson, Deceased, Mike Nevelson, Executor - Page 4

                                                - 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