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E. The Certified Public Accountants
Irwin A. Weiser, a certified public accountant for 38
years, provided accounting services to Beth W. Corp., decedent,
and irrevocable trusts #2 and #3 from about 1964 to 1988. He was
Beth W. Corp.'s treasurer for about 15 years during that time.
He was familiar with Beth W. Corp.'s practices for keeping
records and paying taxes.
Albert W. Todd, a C.P.A. for 33 years, provided accounting
services for decedent, Beth W. Corp., and irrevocable trusts #2
and #3 after Weiser left. He prepared tax returns for Beth W.
Corp., the irrevocable trusts, and decedent's estate. He wrote
checks, made bank deposits, and prepared the books and records
(including financial statements) for Beth W. Corp.
F. Decedent's Estate Tax Return
On decedent's estate tax return, the estate reported a gross
estate of $2,813,175, deductions of $1,772,808, and adjusted
taxable gifts of $595,091.6 The estate did not elect the
alternate valuation date under section 2032.
The estate reported that the value of decedent's Beth W.
Corp. stock was $2,293,800, or $307.61 per share. The estate
6The parties have stipulated that the gross estate should be
increased by $3,343 because petitioner inadvertently omitted a
$1,545 bank account from the gross estate and understated the
amount of life insurance paid to decedent's estate by $1,798.
The parties have also stipulated that decedent's estate may
deduct $1,251 less than it claimed, based on a change in the
amount allowed for executor's commissions and administration
expenses.
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