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estate tax deficiency of $1,361,004.03. Respondent, however,
limited the deficiency asserted in his Rule 155 computation to
$1,071,650, the amount determined in the estate tax notice of
deficiency.
On October 15, 2007, we conducted a hearing on the Rule 155
computation issue. Counsel for both parties appeared and were
heard. At the hearing, respondent’s counsel conceded deductions
by petitioner for the $20,814 in executor’s fees, the additional
$55,000 in Oklahoma estate taxes, and $12,495 in attorney’s fees.
The only remaining issue is whether the erroneous gift tax
deduction allowed in the September 26, 2001, estate tax notice of
deficiency should be included in the Rule 155 computation of
petitioner’s estate tax deficiency.
Discussion
Under Rule 155(a), after the Court files its opinion
determining the issues in a case, the Court may withhold its
decision to allow the parties to submit computations of the
correct amount of the taxpayer’s deficiency to be entered as the
decision pursuant to the findings and conclusions of the Court.
If the parties disagree on the amount of the deficiency to be
entered as the decision, either or both of them may file a
computation of the deficiency they believe to be in accordance
5(...continued)
to the State of Oklahoma.
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