Nancy Silverman and Estate of Sheldon Silverman, Deceased, Nancy Silverman, Executrix - Page 19

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                As of September 27, 1982, respondent transferred $54,372.61                  
          out of Sheldon's and Nancy's 1981 tax liability account and into                   
          their 1980 tax liability account.  This was done in connection                     
          with the September 1982 issuance of the $81,054.77 tax refund                      
          check for 1981, described supra, but the transfer was recorded on                  
          respondent's records as of April 15, 1982.  After this transfer,                   
          the balance in Sheldon's and Nancy's 1980 tax liability account                    
          was zero.                                                                          
                After Nancy filed the amended tax return for 1980 claiming a                 
          $204,868 refund, respondent abated the 1980 income tax liability,                  
          but only to the extent of $55,923.  This abatement then triggered                  
          a refund of tax for 1980 in the amount of $128,715.36.  This                       
          refund consisted of (1) a tax decrease in the amount of $55,923,                   
          (2) an abatement of penalty in the amount of $2,052, (3) an                        
          abatement of interest previously assessed in the amount of                         
          $5,940.40, and (4) interest on the overpayment in the amount of                    
          $64,799.96.  The refund check for 1980, in the amount of                           
          $128,715.36 was issued on February 5, 1988, and was received by                    
          Nancy.                                                                             
          Bank Accounts, Life Insurance, Etc.                                                
                During 1981 Nancy and Sheldon held various bank accounts and                 
          owned stock, as shown in table 7.  Sheldon's two individual                        
          checking accounts were in existence at the time Nancy and Sheldon                  
          got married.  Nancy did not have signature authority on any of                     





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