- 9 - 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.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