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Re: Edith H. Hornberger, docket No. 3656-98:
Addition to Tax
Year Deficiency Sec. 6651(a)
1992 $744,724 $47,810
Re: Estate of Edna B. Hunter, Deceased, Shirley M. Hunter
Administratrix, docket No. 3658-98:
Addition to Tax
Year Deficiency Sec. 6651(a)
1992 $722,052 $180,513
Re: EV Hunter Trust, Shirley M. Hunter and T. William Dowdy, Co-
Trustees, docket No. 3676-98:
Addition to Tax
Year Deficiency Sec. 6651(a)
1992 $722,238 $166,397
The deficiency and addition to tax in each of these
consolidated cases is a duplication of the deficiency and addition
to tax in the other cases.
Following concessions by the parties, the issues for decision
are: (1) Whether interest on estate taxes paid by the EV Hunter
Trust (the trust) in 1988 and deducted by the trust’s grantor,
Edith H. Hornberger (petitioner), on her 1988 amended individual
tax return, and refunded by the Internal Revenue Service (IRS) to
the Estate of Edna B. Hunter, Deceased (the estate), in 1992
constitutes income in 1992, pursuant to the tax-benefit rule, to
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Last modified: May 25, 2011