- 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