- 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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