- 3 -
docket No. 3976-95, respondent determined a deficiency of
$558,272 in petitioner's Federal income tax for 1992. The
deficiency determined in docket No. 3976-95 represents an
alternative position taken by respondent to protect the
Government's interest in the event its position in docket No.
19200-94 is not sustained.
After concessions, the issues remaining for decision are:
(1) Whether petitioner's section 2053(a)(3) deduction for a claim
against the estate is limited to the amount for which the claim
was settled following decedent's death; (2) if petitioner is
entitled to a section 2053(a)(3) deduction for the entire amount
claimed on the Federal estate tax return, whether petitioner
realized discharge of indebtedness income pursuant to section
61(a)(12) when it settled the claim in question for a lesser
amount; and (3) whether the income tax benefit derived by
petitioner as a result of the application of section 1341(a) is
an asset which increases the gross estate.
Background
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts, supplemental stipulation of
1(...continued)
Practice and Procedure.
2Respondent has conceded the accuracy-related penalty under
sec. 6662(a).
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