- 3 - (late filing of tax return) and 6651(a)(2)(late payment of liability shown on tax return) against petitioner in the amounts of $1,732,348, $530,094, and $297,523,2 respectively. By amendment to petition, petitioner claims an overpayment of estate tax. After concessions by both sides, the issues for decision are as follows: (1) What the fair market values were of four of decedent’s real properties on the date of decedent’s death; (2) whether petitioner is liable for an addition to tax under section 6651(a)(1); and (3) whether petitioner is liable for an addition to tax under section 6651(a)(2). FINDINGS OF FACT In General Some of the facts have been stipulated; the stipulations and the stipulated exhibits are incorporated herein by this reference.3 2 In the notice of deficiency, the amount of the addition to tax under sec. 6651(a)(2) was determined as $297,523 “computed to the date of this notice” (Feb. 3, 1997), plus 0.5 percent per month, to a maximum of 25 percent. The proper amount is to be determined in the computation under Rule 155. Unless indicated otherwise, all Rule references are to the Tax Court Rules of Practice and Procedure. 3 At trial, respondent raised certain relevance objections to petitioner’s Exhibits 5 through 8 and 10 through 18. The Court (continued...)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