-3-
may be deducted from the value of the gross estate under section
2053(a)(3). We hold she did not. (5) Whether the expense of 5
years of maid service may be deducted from the gross value of the
estate as an administration expense pursuant to section
2053(a)(2). We hold it may not. (6) Whether petitioner is
subject to an accuracy-related penalty under section 6662. We
hold it is, to the extent set out below.
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference.
Petitioner is the estate of Carolyn W. Holland (decedent),
who died testate, on November 25, 1989, in Atlanta, Georgia
(Atlanta). Lewis G. Holland, Sr. (Lewis), Betty H. Kann
(Betty),3 and Jack K. Holland (Jack) (the executors) are the
executors of the estate. The executors had a mailing address in
Atlanta at the time the petition in this case was filed. For
convenience, we present a general background section and combine
our findings of fact with our opinion under each separate issue
heading.
A. General Background
Decedent
Decedent was born in Atlanta, on July 21, 1914. She was
married to the late J. Kurt Holland (Holland), an attorney who
practiced law in Atlanta. Decedent is survived by three
3 At the time of decedent's death, Betty Kann was known
as Betty Koblitz.
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