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its reply, Exxon denied the interest owners’ allegations and
characterized them as unsupported and incorrect as a matter of
law.
On March 23, 1990, decedent, as executrix of Frankie’s
estate, filed a Form 706, United States Estate (and Generation-
Skipping Transfer) Tax Return.6 The amount of $944,280 was
deducted as a claim against Frankie’s estate pursuant to section
2053(a)(3). The attached Schedule K, Debts of the Decedent, and
Mortgages and Liens, listed a debt described as “EXXON
CORPORATION SETTLEMENT ON OVERPAYMENT OF ROYALTIES”. The “Amount
in contest” was listed as $1,888,777, and the “Amount unpaid to
date” and “Amount claimed as a deduction” were listed as
$944,280. Attached to the Form 706 was a billing statement
prepared by Exxon for the period January 1, 1975, through
February 27, 1986, showing Frankie’s total share of the royalty
interest as $1,888,777. Also attached to the Form 706 was the
letter dated August 30, 1989, from Mr. Kuhlmann to Mr. Knowles,
6Decedent’s name is signed on the line for “Signature(s) of
executor(s)”. The following certification is contained above
decedent’s signature:
Under penalties of perjury, I declare that I have
examined this return, including accompanying schedules
and statements, and to the best of my knowledge and
belief, it is true, correct, and complete. Declaration
of preparer other than the executor is based on all
information of which preparer has any knowledge.
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