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estate, filed Form 706, United States Estate (and Generation-
Skipping Transfer) Tax Return (estate tax return), which showed
estate tax due of $14,573. The estate tax return reported that
decedent’s total gross estate equaled $721,834. Included in
decedent’s total gross estate reported in the estate tax return
was the value of the Seafirst joint account as of the date of
decedent’s death, which the personal representative reported in
Schedule E, Jointly Owned Property, of that return (Schedule E)
as $64,676.1 The value of the Seafirst joint account reported in
Schedule E and included in decedent’s total gross estate did not
include the aggregate amount of funds represented by the November
1995 checks and the January 1996 checks (i.e., $205,000). The
estate tax return did not include as part of decedent’s total
gross estate any amount with respect to decedent’s power to
withdraw.
Respondent issued a notice of deficiency (notice) with
respect to the estate tax return. In the notice, respondent
determined that the aggregate amount of funds represented by the
November 1995 checks and the January 1996 checks should have been
reported in Schedule E. Consequently, respondent increased
decedent’s total gross estate and taxable estate by that amount
(i.e., $205,000). Respondent also determined in the notice that
1The value of the Seafirst joint account reported in Sched-
ule E included $140 of interest that had accrued on that account
through the date of decedent’s death.
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Last modified: May 25, 2011