Estate of Floy M. Christensen - Page 9




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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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