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On January 24, 2002, we entered our decision that there was
a $238,847.24 overpayment of estate tax paid after the mailing of
the notice of deficiency and that there was no penalty due from
the estate under section 6662(a). That decision was appealed and
affirmed and is now final. Sec. 7481(a).
Respondent’s computation contained the following documents:
(1) Respondent’s computation statement, the pertinent
information of which is listed as follows:
Tax assessed and paid $624,594.41
Payments:
July 12, 1991 $60,164.54
April 15, 1993 63,052.00
March 31, 1998 501,377.87
Total payments 624,594.41
Tax liability pursuant to mandate 385,747.17
Overpayment 238,847.24
Penalty sec. 6662(a) None
(2) Form 3614-A, Estate Tax, which recomputed in detail the
estate’s estate tax liability;
(3) Form 6180, Line Adjustment--Estate Tax, which recomputed
in detail decedent’s taxable estate;
3(...continued)
that there is no disagreement that the figures shown
are in accordance with the findings and conclusions of
the Court. In the case of an overpayment, the
computation shall also include the amount and date of
each payment made by the petitioner. The Court will
then enter its decision.
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Last modified: May 25, 2011