- 2 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011