- 5 - agent. At a meeting held shortly after Ms. Braden’s father died, the estate’s probate counsel told petitioners there would be no tax on the distributions because inheritances under $650,000 were exempt from tax. The retired IRS special agent, whom petitioner had met at a class on financial crimes investigations, also told petitioner, in response to petitioner’s question regarding the taxability of an inheritance, that inheritances under $650,000 were exempt from tax. Ms. Braden also received interest earned on certain accounts owned by her father at his death, but the interest income was not reported on petitioners’ 1995 return. Petitioner did not know that part of the distributions received by Ms. Braden consisted of interest income.6 Petitioner believed that all of the funds distributed to Ms. Braden as a result of her father’s death were simply an inheritance from Ms. Braden’s father.7 Ms. Braden used approximately $10,000 of the distributions she received as a result of her father’s death to pay her father’s hospital bills and gave half of the remaining money to 6We infer from the record as a whole that the accounts generating the omitted interest belonged to Ms. Braden’s father before his death and that the omitted interest was part of the distributions made to Ms. Braden as a result of his death. 7Although respondent claims that petitioner did not assert that he is entitled to relief from joint and several liability with respect to the omitted interest income, petitioner consistently took the position throughout the case that he believed the distributions Ms. Braden received as a result of her father’s death were a part of her nontaxable inheritance.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