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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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Last modified: May 25, 2011