David Allen - Page 2




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               Pursuant to separate notices of deficiency, respondent                 
          determined that the Estate of Sloan Allen is liable for Federal             
          estate and income taxes, plus additions to tax, as follows:                 
          Estate of Sloan Allen                                                       
               Estate Tax Liability:                                                  
                                                 Additions to Tax                     
          Sec.           Sec.            Sec.                                         
          Docket No.    Deficiency          6651(a)(1)     6653(a)(1)(A)   6653(a)(1)(B)
          24986-97     $5,835,634          $1,458,909       $291,782            1     
          1   50 percent of the interest on the portion of the underpayment           
          attributable to negligence.                                                 

               Income Tax Liability:                                                  
                                      Additions to Tax                               
          Sec.           Sec.            Sec.                                         
          Docket No.  Year     Deficiency      6651(a)(1)     6653(a)(1)(A)   6653(a)(1)(B)
          24987-97   1987     $278,253      $69,563.25       $13,912.65         1     
          1   50 percent of the interest on the portion of the underpayment           
          attributable to negligence.                                                 
               Pursuant to separate notices of transferee liability,                  
          respondent determined that David Allen is liable both as the                
          fiduciary of the Estate of Sloan Allen (sometimes referred to as            
          Sloan’s estate or the estate) and as a transferee of the assets of          
          the estate for unpaid Federal estate and income taxes, plus                 
          additions to tax, owed by the estate, as follows:                           











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