HomeMy WebLinkAbout12-08-14 Neil Warner Yahn,Esquire
Attorney I.D.No. 82278
James Smith Dietterick&Connelly,LLP
P.O.Box 650
Hershey,PA 17033
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
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INRE: . No. 21 - 10 - 09'� o � � �
ESTATE OF GUOLAUG BRYNJA . � -.�� cr'�'-, cn a
GUOJONSDOTTIR, deceased • `�" � � � T�
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MOTION TO COMPROMISE ,-, o -�'n � =��= C,
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TO THE HONORABLE JUDGES OF SAID COURT: �-�.� '� N U' Q
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AND NOW comes the Petitioner,Neil Warner Yahn, Esquire (herein"Petitioner") of the
Law Firm of JAMES, SMITH,DIETTERICK and CONNELLY, LLP, and as Administrator
of the Estate of Guolaug Brynja Guojonsdottir(herein the "Estate"), who hereby sets forth this
Motion to Compromise upon valid information and belief as follows:
1. Guolaug Brynja Guojonsdottir(herein the "Decedent") died in Reykjavik, Iceland
on December 24, 2008, with a previous principal residence in the Commonwealth of
Pennsylvania located at 2331 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania.
2. Decedent is survived by her five (5) children who are named beneficiaries
(collectively the children shall be called the"Beneficiaries" unless identified individually by
name) under the Estate, namely:
a. Gudjon J. Olafsson who currently resides at 52 Boatswain Drive, Berlin,
Maryland 21811 (electronically at Gudjon.Olafsson@perdue.com);
b. Bryndis Gudjonsdottir/Bryndis Gu�jonsdottir(can be written"Gudjonsdottir")
Reynihli� 4 - 105 Reykjavik Iceland;
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c. Brynja Gudjonsdottir/Brynja Gu�jonsdottir c/o: Halldor Jakobsson Gautavik 20
104 Reykjavik Iceland (electronically at bgbebe65@gmail.com);
d. Asa B. Oates (a/k/a Asa B. Olafsson) who currently resides at 121 Mapleton
Boulevard, Harrisburg, Pennsylvania 17112; and
e. Olafur K. Olafsson who currently resides at 145 Taylor Street, Apartment 608,
San Francisco, California 94102 (electronically at olafur.gudjonsson@gmail.com).
3. On or about February 2, 2009, Stefan Geir Thorisson, Esquire(herein"Counsel
Thorisson"), of Reykjavik, Iceland,was appointed as Receiver of the Decedent's Foreign Estate
by the Reykjavik District Court whereby the Will was probated.l
4. On or about December 2, 2010,upon petition, Ancillary Letters of Administration
were granted to Petitioner by the Cumberland County Register of Wills as Administrator of the
Decedent's Domestic Estate (approximately two years after the Decedent's death).
5. It follows, the Federal Estate Tax Return for the Decedent was late even at the
time Petitioner was appointed and thus penalties accrued.
6. On or about November 13, 2012, Petitioner submitted before this Honorable
Court a Petition to Adjudicate (herein"Petition to Adjudicate")which outlines the procedures
advanced on behalf of the Estate with regards to the Decedent's Federal Income Tax analysis and
Federal Estate Tax analysis,the Decedent's residency (and intent to return)to the United States
during her lifetime and the proposed distribution of her assets,primarily consisting of a TOD
account and an IRA account with Charles Schwab, as outlined in further detail in the Petition to
Adjudicate.2
1Halldor Reynir Halldorsson is now administering the Decedent' Foreign Estate.
z Given the volume of the Petition to Adjudicate,Petitioner hereby incorporates all facts,averments,exhibits and
references made therein as if set forth in full in the present Motion.
2
7. On or about January 31, 2013, this Honorable Court executed the attached Order
(see Exhibit"A") which approves the Petition to Adjudicate and authorizes the administration of
the Estate as reflected therein, including the Schedule of Final Distribution.
8. Consistent with the Order of this Honorable Court, Petitioner submitted the Estate
Tax Return(Form 706)to the Internal Revenue Service (herein"IRS") for processing.
9. On or about September 24, 2013, Petitioner received notice from the IRS that the
Estate Tax Return has been selected for examination and also issued penalties (see Exhibit"B").
10. The Petitioner has been working with Revenue Agent Amy Panebianco, Esquire
(herein "Examiner Panebianco") of the Internal Revenue Service.
11. Petitioner has been in communications with Examiner Panebianco who has
provided Petitioner with a Draft Report which outlines the additional tax assessments the IRS
seeks to impose and an explanation of items related thereto (see Exhibit"C").
IRS CHALLENGE—GIFT OF DONOR—CHESTNUT STREET PROPERTY
12. After several months of discussions with Examiner Panebianco and as provided in
the Draft Report, the IRS has challenged the 2002 gift made by the Decedent to her son, Gudjon
J. Olafsson, with respect to a Fifty Percent (50%) interest in the real property located in Camp
Hill,Pennsylvania (see Page 4 of Exhibit"C").
13. By way of background and as outlined in the Petition to Adjudicate, the Decedent
and her son, Gudjon,then sold the property in 2005 for One Hundred Twenty Four Thousand
Dollars ($124,000.00), and although the Decedent would have been entitled to half of the net
proceeds ($62,000.00), it appears the Decedent allowed her son to keep the entire value (see
Page 9 of Exhibit"C").
3
14. Accordingly, the amount of adjusted taxable gifts needs to be amended to reflect
the fair market value of the above gifts as referenced on Page 16 of Exhibit"C".
15. Indeed, as outlined in the Petition to Adjudicate, allegations have been intimated
that the Decedent's son, Gudjon J. Olafsson, may have self-dealt the proceeds from the sale of
either or both real properties—2331 Chestnut Street, Camp Hill,Pennsylvania(herein"2331
Chestnut") and 1755 Palmer Drive, Turlock, California(herein"I755 Palmer")—to the
detriment of the Decedent utilizing a certain Power of Attorney dated September 30, 2002.
16. Petitioner hereby incorporates all facts, averments, exhibits and defined terms
from the Petition to Adjudicate filed on or about November 12, 2012 as if set forth in full herein
and as further referenced below.
17. Allegations related to the proceeds of the sale of 2331 Chestnut are unfounded as
of today's date and while some monies from the sale of said property are unaccounted for,
Gudjon J. Olafsson, as agent, represents he paid the mortgage from date of purchase and any
amounts paid back to him at the closing on the sale of said property were reimbursed.
18. The deed and mortgage previously attached to the Petition to Adjudicate indicate
that the Decedent purchased 2331 Chestnut in March 1995 for$160,000 and mortgaged the
property via PNC Bank for $128,000.
19. It further appears as set forth in the Petition to Adjudicate, that on or about
February 24, 1999, the Decedent paid off the PNC Mortgage and refinanced the property with
Keystone Financial Bank for$111,600 and the rents are assigned to said institution as collateral.
20. On or about September 30, 2002, the Decedent transferred 2331 Chestnut into
joint names with her son, Gudjon J. Olafsson (it appears the Decedent did so under her own
volition and not under the Power of Attorney).
4
21. Finally, on or about July 22, 2005, Gudjon J. Olafsson, as Agent under the Power
of Attorney, sold 2331 Chestnut for$190,000 to unrelated parties and the mortgage is paid off
(as of July 2005 it appears the mortgage totaled $51,532 and other charges as reflected on the
Settlement Sheet,however, it appears $124,000 was transferred to the Agent under the power of
Attorney and accounting has not been demanded).
22. Gudjon J. Olafsson has represented that he paid the mortgage on 2331 Chestnut
and while approximately$120,000 of the proceeds from the sale of 2331 Chestnut remain
unaccounted for as of today's date,the cost to litigate with Examiner Panebianco and the
inclusion of the$62,000.00 increase (see Page 16 of Exhibit"C") is less than the economics to
litigate the transfer in 2005 when the property was sold.
IRS CHALLENGE - 20 REYJAVKI AND LEGAL FEES
23. Examiner Panebianco is also challenging the value of the real property held in
Iceland by increasing the reported value by$75,894 (increased from $1,111,837 to $1,187,731).
24. Petitioner suggests this increase is attributed to the exchange rate between the
Krona and US dollar(see Line 1 of Page 14 of Exhibit"C") from date of death to date of sale
almost two years later, and not the value of the real property.
25. Petitioner avers the increase in value to 20 Reyjavki is attributed to the value of
the Krona and the value of the real property did not increase by$75,984.
26. The sale price was ISK 120.000.000 and at that time (March 21, 2011), the rate of
the Icelandic Krona vs US Dollar was 114.18, which is higher than the date of death value.
27. Petitioner is in the process of reconciling this before the IRS and believes this
deficiency will be settled given the underlying value of the real property did not increase from
date of death, only the exchange rate for the Krona when contrasted to the US Dollar.
5
LEGAL FEES AND CONCLUSION
28. As of the date of the initial engagement in 2010 until last May of 2014, legal fees
totaled approximately$145,000 over the four year period and since that time, an additional
$7,000 in fees have been incurred to address the issues surrounding the foreign withholding
income tax obligations for the IRA/TD Accounts and reconcile the above Estate Tax matters
which remain unpaid.3
29. It follows, Petitioner expects the fees to be approximately another$5,000-$10,000
to close the matter with the IRS and before this Court, however, clarification of residency status
has saved the Estate substantial monies.
30. As of the date of this Motion, it appears Petitioner has reconciled with the IRS the
waiver of the 20 Reyjavki assessment and a new resolution will be forthcoming, and thereby
Petitioner requests the authority to negotiate out the final payment for the IRS examination and
coordinate payments from Halldor Reynir Halldorsson, at Forum Logmenn, Reykjavik, Iceland
(www.forum.is), counsel for the Decedent's Foreign Estate.
31. Petitioner hereby seeks approval and authority from this Honorable Court to
compromise and satisfy the aforementioned tax assessments as reflected herein.
32. As Attorney Panebianco has indicated in previous correspondence, "[i]f the estate
agrees to the adjustments, the estate is also entitled to a deduction for any interest accrued on the
deficiency" (see Exhibit"D").
33. Petitioner is desirous of satisfying the aforementioned deficiencies as soon as
possible to take advantage of the waiver of interest (and possible waiver of the alleged increase
in 20 Reyjavki as well).
3 Petitioner coordinated that the broker is obligated as a withholding agent of the US sourced income tax(distinct
from Federal Estate tax)(to a foreign person)and that a withholding agent who fails to withhold is liable for the
uncollected tax consistent with Code §1461 of the Internal Revenue Code.
6
WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an Order
permitting the Domestic Administrator of the Estate of Guolaug Brynja Guojonsdottir, namely
Neil Warner Yahn, Esquire, to compromise and satisfy the aforementioned tax assessments as
reflected herein and request such payments from Halldor Reynir Halldorsson, Attorney at law at
Forum Logmenn, Reykjavik, Iceland, counsel for the Decedent's Fareign Estate.
Respectfully submitted,
JAMES,SMITH,DIETTERICK& CONNELLY,LLP
B . �. _.--..._.-.—..._.._..__
Date: � �� s � � Y�
Nei1��Ya , Esquire
Attorney I. . No. 82278
134 Sipe A enue
Hummelsto€wn, PA 17036
(717) 533-3280
� Petitione `
7
VERIFICATION
I, NEIL WARNER YAHN, ESQUIRE, verify that the statements made in the foregoing
Motion are true and correct to the best of my knowledge. I understand that false statements
herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to
authorities.
� _�..._.___ __
Date: ►�- � s� ��+ �--
NEIL WA ER YAHN,ESQUIRE
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IN THE COURT OF C�1VIMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
Il�T RE: . I�To.2i—l�i-0973
�STATE OF GUOLAUG BRYNJA .
�UOJUNSDOTTIR,deceased .
�RDER OF COURT
AND NOW, this �1 yt day of ��� , 2013, upon consideration of the
Petition to Adjudicate and having not been presented with any Objections thereto by the
beneficiaries of the Estate of Guolaug Bryr�ja Guojonsdottir, it is hereby ORDERED and
DECREED that the Schedule of Final Distribution as reflected in Exhibit "D" of the Mot�on tc�
Make Rule Absoiute is APPRQVED. The Donlestic Adininistra#or af the Estatc of Guolaug
Brynja Guojonsdottir, namely P•Ieii Warner Yahn, Esquire, shail advance the administration of
said Estate conszstent with the terms of the Schedule of Finai Distribution.
BY THE COURT,
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DISTRIBUTI�NZ1'ST.� � �;,,.r._ �,� _; ,Y s
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Neil W. Yc�hn,Esguire,James;Smith,Diettericlt&Connelly,LLP,PD Box 550,Hershe�j'fF=X�;�3;�itiortef .
Gudjon J. Olafsson,S2 Bvatswain Drive,Berlin,Maryland 2�811 " "F :^` `��' �"
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Bryndis Guojonsdottir,Reynihlid 4-105 Reykjuvik,tceland '�"r "' - =,:1 ,
Brynjn Guojonsdottir,20109 Reykjaviklceland(counsel will sen�e electronically) � y � f�, �;.
A,ra B. Oates, 121 Mapleton Blvd, Harrisburg,Pennsylvania 17112 , ;, ° ,,r,
Olafur K. Olafsson, 14 S Taylor Street,Apastment 608,San Francisco, C¢lifornia 941 d�` �,:r'r "� "��
Stefan Geil 1'horisson,Adulstraeti 6, IS-101 Reykjavik(counsel will serve electronicallyj
.�ndrerv Cooper, Charles Schwab Retirement&Estates, 8332 Woodfield G•ossing 131vd, Indianapolis,IN 46240
Pennsylvania Department of'Revenue,Bureau oflndividual Taxes,,F.O. Box lgJb'Ql,Har-��isburg,PA 17128
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�� DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
'� Washington,D.C.20224
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SMALL BUSINESSlSELF-EIYIPLOYED DtVISiON
Date: September 24, 2013
Neil W. Yahn
PO Box 650
Hershey, Pennsytvania 17033
Dear Mr. Yahn,
The Intemal Revenue Service has selected the tax return filed on behaff of the
Estate of Guolau� B. 0lafsson for examination. To aid in completing the
examination as quickly as possible, please mail the following information to me
by October 24, 209 3.
Schedule A, Items 9 and 2:
a. A copy of the appraisal. If not based on an appraisal, please provide information
on haw the value was determined;
b. Please suppiy a copy of any other appraisals regarding the subject which may
have been made within three years of death, either before ar after,
c. If rented or leased, a statement of rental income and carrying ciiarges for the
years 2004, through 2008;
d. If leased, a copy of the contract;
e. A detailed explanation of any property sales or attempts to sel! before or after the
valuation date; include capies of all iisting agreements, contracts of sale, and
closing statements;
f. Did Mrs. Olafsson own any reai estate in Cumberland
County? 1 had a done a public record ssarch and found that
she might have owned a property located at 2331 Chestnut
St. Camp Hill, PA. If she did own this pro,perty at death,
please provide an appraisal of value#or the time of death. If
she had #ransferred this property to another individual prior
to her death, please provide evidenc+e of the transfer and the
valus at the time of the t�ansfer.
2. Schedule G: ( have attached a valuation of the items listed on the
schedule G. Some of#he items had accnred dividends associated with
them that need to be re�rted, while others were trading ex-dividend and
therefore had an adjustment in the price. Please review the valuations. If
you have any questions, please let me know.
3. Schedule J: Executor and Attorney Fees: Please fill out the enclosed
form 4429 regarding the attorney and executor fees.
4. Also, please provide the information indicated by�(on the enclose.d chedclist.
In your cover letter retuming the above, would you please alsa state:
{A) Whether any assets shown on the estate tax retum have been sotd, or the
subject of a sales or purchase a�Fer within three years of the date of this
letter(and if so, please state the date, price and terms);
(B) Whether yau have had an appraisai made (other than those attached to the
Form 706 when originally fiied, if any)within three years of the date of this
letter of any asset included in the decedent's gross estate (and if so,
pfease attacli copies);
{C) Whether any additional deductions or assets have come to your attention since the filing of
this return;
(D) Whether ar�y"amended"estate tax retum(s) have been fifed.
Enclosed are Pubfication 1 and Natice 609, and Form 2848, which is a Power of
Attorney. Form 2848 should be campleted and returned as quidcly as possible so that I may
begin corresponding with the accountant, attorney or other agent designated to represent the
estate/taxpayer before the Internal Reve�u� S�r�ice. The power of attomey shouid be
executed for the estate tax, any post-1976 gift tax, and any estate fiduciary income tax return(s).
Please mail this information to me at the following address:
Internal Revenue Service
230 Executive Dr.
Suite 104
Cranberry Township, PA 16066
Should you have any questions, please call me at 724720-2019.
Sinc rely, r. ,
,��u� ��...G+.�,�-t�.���
Amy P�fiebianco
Attorney{Estate Tax)
Enc:
Publication 1
Notice 609
Form 2848
Form 4421
REQUEST FOR INFORMATION--ESTATE,GIP"I'OR GENERATION SKIPPING TRANSFER TAX
Please make rhe foIlowing items available per instructions. Photocopies are acceptabtc.
GENERAL INFORN[ATION/PERSONAL RECOR115. ❑ Copy of the cooperarive%ondominium agreernent
❑ Certified copy of death certificate. including any resLr�Gtioas on transfer and use of the
� Certified copy af the Last Will and Testament. property.
❑ Bank statements and cance[led checks fvr
�21'011g�1 . Include statements Of aCCTuet'� CLOSE CORPORAT'ION DATA FOR TIII200GH
interest up to date of death, if any. (Schedule , SC[�nU[,E(S) ,ITEM(s)
Item(s) } ❑ Balance sheets and profit and loss statements.
❑ Passbooks,bank ledger cards or other statemetrts from C7 Copies of Forms 1 1 20/1 1205. Include audit reports
savings or money market accounts of which decedent and closing agreements where applicable.
was owner,joint tenant, or trustee for tt�rough ❑ Complete f��nancial statements.
. Include statements of accrued interest up to ❑ Statement of dividends paid.
date of death,if aay.(Schedule ,Item(s)^� p Statement of officers' sataries, bonuses and other
O Investment, znutual fund and/or brakerage statements benefits.
for tluough . (Schedule , Itern(s) ❑ Statement of date atid state of incorporation, number
} of shares outstanding, shareholders' natnes, and
❑ Statements of all credit card accounts for one full year number pf shares each holds.
preceding deatk�. ❑ Descriprion of the primary fuqction of the corporation.
✓ Copies of all Powers of Attomey executed, held or O All buy-sell agreement�.
exercised by d�cedent.
✓ Trust documents for all trusts of which decedent was a PAR7'NERSHIP DATA FOR TH1i0UGH
trustee,grantor or held a power of appointment. SCttEnu�.E(S} ,ITEM(S) �
✓ Copies of the decedent's Federal and 5tate income tax ❑ Parmership agreeuzent
returns for 2006 through 2008, including any ❑ Descripdon of h�w the partnership business is
examination reports thereon. conducted.
✓ As to any predeceased spouse, atl probated wills with ❑ Balance sheets, income statements and camplete
cadicils, trust agreements pertaining to decedent, financial statements.
estate tax returns and closing letters with adjustments ❑ Incame rax rehuns(Form 1065)with K-Is.
(where applicable), all Form I041 returns, final tax D Names and relationships of all parqiers and the'v
bill,and all trust accountings. percenta�e of ownership.
✓ Copies of al] Forms 709 f�led, with copies of a Deseription of each partner's inierest, including the
examination reports and closing letters, if applicable. date and mamier of acquisition.
If gift was split with spouse, incIude spouse's 709 as ❑ Descri}�tion of alt restrictuons nnposed on the parmers
well. with respect to their partnership interest.
❑ All assignments ofpartnership interests.
ESTATE RECORAS.SCHEDULE(S)
✓ Compieted Form 2848 Power of Attorney.(Enclosed) ADDiTIONAL INFORMA'fXON
✓ All Federal fiduciary income tax retums (Form 1041) C] Por Schedule , Item{s) : Proof of
filed by the estate,including all schedules. con�ibution per IRC Sec 20,2040-1.
❑ Estate's financiat records inclnd'mg bank statements, ❑ For Schedule , Ttem(s) : Appraisals of all
cancelled checks and letlgers, copies of all accountings personal properiy fucluding, but not lim.ited to,
filed. fi�rniture and furnishings, art, jevvelrY, china and
✓ AcCotlnt aud adjudication,if filed. silver. If sold,the sale price, date of sa[e, forum, and
✓ Completed Form 4421 regarding unpaad executors' buyer's name. If ta be auctioned, provide the date of
commissions or attorney's fees.(Enciosed) suc#ion,auction house,and reserve price.
�/ Copy of the State inheritance tax return filed. C] For Schedule ,Item(s) : Forms 712 for atl
o Proof of paymern of State and/or foreign inheritance Life Insurance olicies.
p (Enctosed).
taxes. (Form 3-215 enclosed.) q For Schedule , Item{s} : copy of ioan
agreement.
REAI,EsxA�. SCHEDULE{S) ,ITEM(s)
❑ Copy of appraisal or other basis for valuation.
CI If sold,a cop�of tt�e closing statement and corrtract of
sale.
❑ If leased,a copy of tbe lease agreeman�
❑ Statement of rental income and catrying charges for
through
❑ Homeowner's insurar�ce policy with a!1 riders
attached.
.�.--��.
Eatate valuatioa
Dat,� af Deeth: 12/2412QOB Eetnta of: GUOI,At1G gRxNJp Gt1�pJCNgnpTTZR SCSI.G
Valuation Date: 12/24J2008 Re�ort Type: Date of Daath
Prooaaeing Date; 02/O1/2013 Nusber of 9scuritiae: 13
Fi1e ID: G3412C-13
8hares BqCurity l4pan and/or 8VP P�aturn Ditfrrpace
or Par Deeariptiou I{igh/Aek LOM/8id usjustmente va1uQ/aocrua�, yaive/�►c�=„u yai„e�r►ccr„al
1) 6665.217 AII�I EQVI27 FDS ,ZNVESCO EQL FDS (OOI413194; LC6I]h
INVBC DVBFA Il7V
Mutuc�l Fund (as quot�d by NJ1SbRQ)
12/24/2008 6.62000 Mkt
8.620000 57�462.99 57,462.79 0.00
J �f p.00 0.00
2) 56fi.236 At+�RIGN C6Nri Gpv�P n�C90adB Ttt (025081605; 8C�lfq
GIL�TT& b1AS IIiV
Mutu�l Yund (se 9uot�d bY �A�AQ)
12/24 J2008 10.51000 l�ct
30_510060 5,95t.14 5,95I.14 0.00
Daily Div, lu;crval ac oE 12/24/2408 15.53 0.00 15.63
3) 7/8.07 Cash �B8) ?48.07 748.07 0.00
� 0.00 O.OG
4) 2591.8Q9 NWE�N INVT FDS INC (587{23260; 8b�diX►
SC7►P SEL CL A
�tuai lwnd (as quotod bY N7�DAQ)
�.z/s�/sooe �.za000 ao�t
7.280000 1$,868.37 16,668.37 0.00
o.00 o.oa
5) 985 IS[iAREB TR {464287909; IVW)
SiP500 GttN
N7[SE 1►rCaG �qu3ties Bx�anqe
12/2�J2008 43.29000 �2.92000 H/L
43.105000
Div: 0.201310 Ex: 12/24 Pec: 12/29 Pay: 12/31/08 + 0.201310
93.306310 �2,656.72 42,db3.35 193.37
0.00 0.00
6) 494 iBHAR�B TR (4642B740A; IVS)
Si�P 500 VALpE
NYSE 11rca 6quities Exchange
12J2¢/2008 43.30000 d2.A3000 H/L
43.065000
Div:��Br:46$49Q E�: 12/23 Ree: 12/29 Hay: 12/31/08 + U.468480
43.533�80 21,505.54 21,276.58 228.96
0.00 0.00
�f a5o isx�s rR �as42s�zoo; rvv�
CC7ii8 SGP500 ETF
NYSE 11raa 8quitiee �zchar�qo
12/24/2008 87.09000 86.2330D H/L
86.66150D
Div: 0.661760 �z: 12J24 R4c: 12/29 Pay: 12/31/08 + 0.661760 �
e7.323260 39,295.47 38,997.00 298.47
0.00 0.00
B)� 23559.5 SCR9WIH CB71RL�9 F�1t�i,x Efl (SNLXx)
11DCA8FIRP�V PR$W
12/24/2Q08 1.OQ000
1.000000 23,559.50 29,559.50 0.00
O.OQ 0.00
9) 1664.698 MfA�IDLR SRR TR (626124242; Mf�OYX}
t�CAP OOQt QR 7
lslitttal P11ild (AC qUOtld bY NABDI►Q)
12/2�/2008 16.31000 �ct
16.330000 27,i51.22 27,151.22 0.00
0.00 0.00
10i 1406.735 OPPBN�II�R CI,dHAL FD (68392�104; OPPIIXy
CL A
Mhitual Ewnd (as quot�d by N�?
i2/24/2QOB 36.60000 l�ct
' 36.600000 51,486.50 51,486.50 0.00
0.00 8.00
Page 1
Thia x�port pae produc� sith EstateVai, a product of sstat� Valuations � erieing syrtems, Inc. If yov hav� questiona,
pleaaQ aontact !VP eys�s at (818) 313-6300 or Nxx.6vgsps.cos. (Aevision 7.3.1)
Eatate Valuation
,o of Dtath: 22/24/2008 Eetata of: GLTp�,p� g�y�A ����� g�.G
aluatfon Date: 12/24J2008
Proc�ssing Data; 02/01/2013 . �rt 'lYrpa: Date of Dcath
N�� a� ��itiea: 13
Fi�e ID: G3�12G-13
$haz�s Security I�an and/or avP Return DiPPerenae
or Par Deacriptian High/Ask Lox/Hid Adjuato9RtA VA1W/AOCs.'u91 Vdll1�/AOOTu81 Va171p/AeCTt7a1
li) 10276.404 PIl�CO 8p8 pAC I�VT M@iT 8� (693390445; PRR'AXy �
i'OTAL R6T !1
l��ual Fvnd (as quoted bY NxBDAQ)
12/24/200B 30.05000 Mkt
Daily Div. Accsval as of 12/2a/2008 ' 10.050000 103,277.86 103,277,95 • 0.00
203.�� �'F 0.00 203.14
12) 1152,H33 8(�DUT 1rDg (g02811108; n[�c)
A�'PEI�ITL FD
Mutual FS�nd (a� quotad bY NA8DA�?)
12/2a/20�8 20.94000 t��Dct
20.990000 24,140.32 24r14Q•32 0.00
D.00 0.00
13J 2273.685 AfEI+L8,�1riG0 FD8 TR (9d9915190; SbA,'�Dg}
NFA �P MC 1/i, IN�r
Mutual PSaad (as quoted by NI►gDA,Q)
12/2!/200B 12.95000 LO�t
� 12.95000D 29,446.22 29,444.22 p,pp
D.00 0.00
value:
,ilaczval: $415.547.72 $4��,B26.92 $720.60
Total: $495$766.79 $44�,826.92 �219.07
$939.BT
.•'f
Page 2
Th�a rePox� xaa PZaduoed �rith �stateVal, n product of Sstato yaluetiona t Pricinq 8yatsms, Inc. If you ha�vq q�yaa�ion��
pleas� oontact LV8 Syetme at (818) 319-6300 or ariv.evpay�.aoa�, (A�vieion 7.3.1)
�� ��i� 1�e��rr �igi�t� �� �
Department of the Treasury ����G���
Internal Revenus Service
PubllCati� 1
(Rev.September 20f 2)
Catalog Number fi4731 W The first part of this publication explains some of your most impw'ta»t rights es a
www irs.gov t�Y�The second pe�t explaias the examinaflon,apPeaf,collection,and refund
processes.Thls pubJication is also availabJe M SpaMsh.
, �
I
� � . i f . i . ' i
( �
� I. Fru�e�ti�r: cf'�'c�r.��.�g�i�s V. ��yr���-��o��rty tMe �
� IRS emplaye�wiil e�cplain and protect ��''����`���Q"��t�� ��"� �
i �r�h�es�taxpayer throughaut your You are responsible for payfng ony the
,( correct aur�ourrt of tax due under the
�� law—no more,no less.If you cennot pay all a
�3. ��wVLC!,*d::s �your tax when ft 1s due,you may be able (
� ta make monthly fnstaliment payments. �
�_ �*�t.fidc��t��iaxi�ty
�� The IRS wH(not disGose to anyar�the . ,,. �
�` information you give us,exoept as °`��• ����� �9't�i ��+�'•'��Pt�E�i `��Y �
authodzed by law.You have the right to �i��}��I1'SS
.�__ - .r_._ _. � know why we are asking you for �
� ' � �"�' �` y intamaUon,how we wii!usa it,and what The Ta�cpayer Advocate Servioe can heip (
�� ha�ens if you do not provide requested you'rfyou have trfed unsuocessfuily to �
TNE�RS ►rlISSIG�N informatEon. resoive a problem with the IRS.Your local �
Taxpayer Advocate can offPx you spAcial �
PROVIDEAMERICA'S �� ���. ;`s�' � �• � •,;.;� - h�lp�Y«�have a sigNfic�rtt hardship as a
,� G.�.r S.t s,.c.. c�f l� r e s u l t o f a t a x p ro b l e m.F o r m o r e ��
TAXPAYE'RS 7'QP QUALITY 'i �!'s?z3�a�t3t�'S�LF^'at�� information,call tall free 1�877-777-4778 �
( (1�00-829-4059 for TTYICUD)or write to ,
� the Taxpayer Advocate af the IRS office
SERVICE BY HELP/NG THEM � If yau beliave that an!R8 employee has aot that Iast contacted you. I
i treated you in a professional,fair,and
UNDERSTAND AND MEET ti c,ourteous marner,you should tell that �
: employea's supervis�:If the supervisor's �
THElR T,4X R�ESPONS181L1T/ES s� response is r�t satisfactory you should �r'��.�+�Iya�l�E3fft±,,�L�:ll�i�!
AND BYAPPLYING TN�TAX �i �ite to the IRS hcrector for your area or the ����i„��{
I cerrter whers you file your ret�rn.
LAW WlTN INTEGR/TYAND �j n you disagr+�wlth us about cne sma,nt ot M
FAIRNESS T4 ALL. � ��f �Lp��������'��S your tax liabtlity or aertalin collection
Y actfon.a,you hsve the right to ask the
y,,,. _ i You may elther nepresent yourself or,with '���$��ce to review your ca�.You
� P�Per written authoNzation,have someone "�ay also ask a court to review your case.
el�represent you In your plaoe,Your
�: representative must be a person allowed to
� practice before the IRS,such as an '����:. :�'t�'.li�G#��f'f3.1: �;i'�'�ctin
�" attomeY�cerEified public acc�untarrt,or �4'i1�3�'{'�8S i!�€� �fiaf:'l�Sf
enrdled agent.If you are in an infervlew
� and ask to consoft such a person,then we
� must stop and resch�dule the intervlew fn The�R�will waive penaltiss when allowed
mast cases, bY�w�you can show you ected
`• reasonably end in good faith or relied on
E� You can have someone a t�j��'�advice of an IRS employee.
•� at an Interview,Yau may make�o�Y� ��II waive interest that is the resuk of
i i recordings of any meetfngs wkh our �►�in errore or de(ays caused by an IRS
�; examinatlan,appeal,or coilectiat ���y��
jpersonnel,provided you tell us in writing 10
� days before the meeUng.
�I
1�
�'
••_.__..
spouse relief,see Publication 971,Innocent
w ' i �r ` # � Spouse Reiiei,and Form 8857.
� � . � �O�'4'tt�:�+,��.�:I:Ci �°21'�y
t'iC`"t'�si:�G'w�'
�'.r:5�':1=;Ys1�L0;yS��UC��''i3� we can see ff we should discontinue ihe G���h'�the IRS will deal direcily with you
examination. or your duly authorized repressntative.
We accept most taxpayers'returns as filed. Nowever,we sometimes taik with other
!f we inqulte about your retum or select it ����F� persons if we need Information that you
f�examination,it does nai suggest that �f you do not agree wRh the examiner's �ave been unable to provide,or to verify
you are dishonest.The irtquiry w sed chan es ��t��ion we have recelved.!f we do
examinatian may or may not result in more p�° 9 ,frou can appeat ihem to ���other persons,such as a nei hbor,
tax.We may close your case without «�pe�s Office of IRS.Most differences 9
can be settled without e e bank,employer,or employees,we will
change;or,you may receive a refund. � ��e a^d generally need to te0 Yhem timited
time-consuming court trials.Your appeal i���a�,���
The process of selccting a retum for rights aroe explained!n de#ail in both You�'name•The law
examination usuaily begins in one of two publication 5,Your Appeal Rights and How ��f�us from disclosing arry more
waya First,we use computer programs to To Prepare a Protest ff You pon'#Agree, infortrtiation Yhan is necessary to obtain or
identify retums that may have ir�rect . and Publication 556,F�caminatian of Verify the infomnada�uye are seeldng,Our
amaunts•Th�e pragrams may be based R�ums,Appeal Rights,and Claims for need to cantact other persons may
on fnformation returns,such as Forms p��d coMlnue as long as there is activity in your
1099 and W-2,on studies of pest �f Y���t���u�me case•If we do oontact other persons,you
examinations,a on certain Issues APt�a�s have a rlght to request a list of those
ide►rtified by compliance projects.Second, ��or disagree with its findings,you contacted.
we use irrformation from outside sources m8Y be able to take your case to the U.S. fy �,
that indlcates that a return may have T��urt,U.S.Court af Federal Clafms,or �n��Usltlo
incorrect amounts.These sourcea may t�U.S.District Caurt where you five.If You may f�7e a Gaim for refund if you think
fnciude newspapers,publlc records,and YQu take yo�r case to court,the IpS wili you pa�xpo much tax.Ya�must eneraf
individuals.ff we determine that the have the burden of pr�oving certaln tacts if fi��9 daim v�thin 3 years from the datey
information is accurate and reliable,we Y°�kept adequate rec�ords to show your y�flled your original retum or 2 years from
may use i:to select a retu�for �x Ilabllity cooperated�rfth the lRS,and ��tti�y����e tax,whichever is
examinatlon. +►�eet certain other conditions.tf the court ���,The Iaw generally provides for interest
Publication 556,Examination af Retums, agrees with you on mosi Iss�s in your on your refund if it is not pald within 45
Appeal Rights,and Clairr�for Refund, ���f�d�nds that our positian was iargely days of the date you ftled your return or
explains 1he rules and procedures that we � Y�rnay be able to recover clafm for refund.PubHcatlan 556,
some of your adminlstrative and litigation F�mination of Returns,Appeal Rigtrts,
follow in examinations.The fallowing costs.You will r�ot be ell ible to recover
sections give an ov�v(ew o#haw we 9 and Glaims for Refund,has more
these costs unless you tried to resolve your inforrrration on refunds.
conduct examinations, c�e administr-atively,including gang
t?�+;�;�;j� through the appeals system,and you gave If you were due a refund but you did not
We handle man examinatio�and us the irtTormation necessary ta reso3ve the file a returr�,you generally must file your
y �, return within 3 years irom the date the
inquiries by mail.We will s�d you a ietter retum was due(lncluding extensions)to get
wkh either a reqt�est for mae inforrnation (�p���,sCt�Cry:� that refurxl,
or a reason why we believe a change to pUblication 594,The IRS Collection . r
your return may be needed.You can �£:x �i'tfvt'�'tl��If�t:
respond by maif or you can request a P�ss,eacplair�s your rights and
personal lnterview with an examiner.H you r�p°��lities regarding payment of The IRS provides ihe following sources for
federel tsxes.tt describes: forms,publicatlons,and additfonaf
mafl us the requested information a infortnat(on.
provide en explanation,we may or may not •What to do when you owe taxas.It .TyX�����_g�_a�_�040
egree with you,and we will explaln tFie descrlbes what to do If you gef a tax bili �1_gpp_������m,RDD
reasons for ar�y changes.Please do not and what to do if you thfnk your bilf is .F�S end PuWicsffens: ,
hesitate to write to us about anything you wrong.lt also covers making installment 1�_�9_3g�s(1-$00-829-4p59 for
do not understand, peymeMa,delaying collectiort action, ny/TDD)
�}ls�.�r►riew and submftting an offer in compromise.
•iRS coliection actians.!t covers Nens, `��m°��'lrs.gov
If we notiy you that we w311 canduct your •SmaN Buslness pmbudsman:R smaff
releas�g s lien,levies,releasing a levy,
examination through a personal interview, �ures and sales,and release o# busineas er:tlty can particlpaie in the
or ya�request such an intenriew,yau have P��y repulatory process and commerit on
the right to ask that the examination take enforc�nent adions of IFiS by calling
place at a reasonable time and place that is Your collection appeal rlghts are e�lained 1-888-REG-FAIR.
convenler�t for botl�you and the IRS.If our in detall in Publication 1660,Collectiah •7y�.y�s�y,�n��r����rax
examfner propoaes erty changes to your ���R�9h�• AdmMlstratlasn;Ya�can confidentially
retum,he or she will explain the reasons for 'snr,ocent�pruse Rel1�f report mis�nduct,waste,fraud,or
the changes.lf you do not agres wtth these ����y �th you and your spouse are ��SB by an!RS employee by calUng
changes,you can meet with the sxaminer's t-800-366-4484{i-800-877-8339 for
each responsible for payfng the tul! ny/TDD).You can remain anon mous,
sup@ry�s°r emount oi tax,lnterest,and penalties due Y
�epest�;LCr•.;1'�i@ors on your Joint retum.However,lf you
If we examined your retum for the same quallfy for innocent spouse relief,you may
items in either of the 2 previous years and be relleved of part or all of the joint
proposed no change to your tau Ilability, liabUlty To request relief,you must file
please carrtact us as soan as possible so F°rm 885��Request for Innocent 5pouse
Rellef.For more informatlon on innocent
� PHMad on r+�eyaf�d pspv
11J20/2014 4: 13:09 PM —0600 IRS PAGE 1 OF 20
INTERNAL REVENUE SERVICE �� I��
FAX TRANSMISSION
Cover Sheet
Date: November 20, 2014
To: Neil W. Yahn, Esq.
Address/Organization:
Fax Number: {717) 298-2077 Office Number: 717-533-3280
From: _ Amy Panebianco
Address/Organization:
Fax Number: (877} 879-1646 Office Number:
Number of pages: 20 lncluding cover page
Subject:
Dear Mr. Yahn,
Enclosed please find the reports for the estate of Mrs. Olaffson. Please note, that the tax was decreased
from the previous report based upon the way the gifts were reported. A gift was shown in 2002 for the
transfer of a % interest in the property to the Mrs. �laffson's son and then a gift was shown in 2005 for%2
of the net proceeds she was entitled to receive, but allowed her son to keep. My manager currently has
the case and is reviewing it and then it well be sent to Tech Services for the issuance of the 90 day letter.
Amy Panebianco
ID#0349494
Attorney- Estate Tax
This communication is intended for the sole use of the individual to whom it is addressed and may contain confidential information that is privileged,
confidential and exempt from disclosure under applicable law.If you are not the intended recipient,you are hereby no6fied that any dissemination,
distribu6on or copying of this communication is stricUy prohibited by the provisions of the Intemal Revenue code. If you have received this
communication in error,please contact ihe sender imnediately by telephone.Thank you.
11/20/2014 4: 13:09 PM -0600 IRS PAGE 2 OF 20
SB/SE Territory East
230 Executive Dr. Suite 100
Cranberry Twp. PA 16066
Phone: 724720-2019
Fax: 724772-5110
E-Fax: 877-879-1646
This communication is intended for the sole use of the individual to whom it is addressed and may
contain information that is privileged, confidential, and exempt from disclosure under applicable law. If the
reader of this communication is not the intended recipient or an authorized agent of the intended
recipient, you are hereby notified that any dissemination, distribution, or copying of this communication
may be strictly prohibited. If you have received this communication in error, please notify the sender
immediately and delete the original and all copies of this communication.
11/20/2014 4 : 13:09 PM -0600 IRS PAGE 3 OF 20
Report of Gift Tax Examination
Donor Social Security Number Date of Gift
Gudlaug B. Olafsson 206-56-3412 2002
Shown on Return/
As Previously As Corrected
Assessed
1. Total value of gifts of donor 0 55,972
2. Amount of gifts attributable to spouse � �
3. Gifts of donor less attributable to spouse 0 55,972
4. Gifts of spouse to be included p 0
5. Total giffs(trnes 3+4) 0 55,972
6. Total annual exclusions 0 10,000
7. Total included amount of gifts(Line 5-6) 0 45,972
8. Gift to spouse with MD claim 0 0
9. Exclusions attributable to gifts on Line 8 0 0
10. Marital deduction(Line 8-9) 0 0
11. Charitable deduction(nef of exclusions) 0 0
12. Total deductions(Lir�es t0+»� 0 0
13. Tentative taxable gifts(Line 7-l2) 0 45,972
14. GST taxes payable 0 0
15. Taxable gifts for period(Lines 13+l4) 0 45,972
18. Total taxable gifts for prior periods 0 0
17. Total taxable gifts 0 45,972
18. Tax computed on Line 1 0 9,633
19. Tax computed on Line 16 0 0
20. Total tax payabfe on taxable gifts 0 9,633
21. Unified creditfrom Table B 345,800 345,800
22. Unified credit for prior periods p 0
23. Balance(Line 21-22) 345,800 345,800
24. 20%specific after 9/8/76 0 0
25. Balance(tine 23-24) 345,800 345,800
26. Unified credit(Lessorotlines 20ar25) 0 9,633
27. Credit for foreign gift taxes 0 0
28. Total credits(Lines26+27) Q 9,633
29. Balance(Lrne 20-28) 0 0
30. Generation-skippingtransfertax 0 0
31. Total tax(Lines 29+30) 0 0
32. Tax previously assessed(From Lrne 31) p
33. Total tax increase/decrease(Cine 31-32) �
34. Penafties previously assessed �
35. Penalties as corrected code(s) �
36. Net penalties increased/decreased(Line 35-34) �
37. Increase/decrease in tax and penalties(Lines 33+36) �
Form 3233(��-20�2) Catalog Number 19401X publish.no.irs.gov Department of the Treasury-Internal Revenue 5ervice
11/20I2014 4 : 13;09 PM —0600 IRS PAGE 4 OF 20
Form SSs-A Schedule number a�exhibit
(Rev.January1994) EXPLANATION OF ITEMS GiftsofDonorwloGST
(Schedule A Part 1)
Name of taxpayer Tax Identification Number YeadPeriod ended
Gudlaug B. Olafsson 206-56-3412 2pp2
Gifts of Donor w/o GST (Schedule A Part 1)
Item# Description Returned/Assessed Corrected
New Gift of Real Estate located at 2331 Chestnut St. Apt. 2, Camp Hill, F 0 55,972
Total of these Items ��972
Shown on Return p
Change to Schedule 55 9�2
In September of 2002, the donor tiitled her propery located in Camp Hill in the name of herself and her son, ,
Gudjon J. Olafsson as joint tenants with right of survivorship. The property had an assessed value of$199,280
at the time of the transfer In 2005, the property sold for$190,�00. No appraisals have been done on the
property. A sale can be used as the best evidence of fair market value. See Giovacchini, Shirley C., Est,
(2013)TC Memo 2013-27, RIA TC Memo¶2013-027, 105 CCH TCM 1179(e, g); Brown, Adelia E. Est v. Com., (1970,
CA5)25 AFTR 2d 70-1610, 425 F2d 1406, 70-1 USTC¶12683, affg(1969)TC Memo 1969-91, PH TCM¶69091, 28 CCH
TCM
497(e); Max Shlensky, (Blanche Siegei) (1977)TC Memo 1977-148, PH TCM P 77,148; Keitel, Frederick J. Est,
(199�)TC Memo 1990-416, PH TCM¶90416, 60 CCH TCM 425 and
Levy v US, 402 Fed.Appx. , 0 L 42 . (T . 1 1�-2 USTC P 60,608.
The value of the property at e � ��int ith t c Y� s$1 .T re was a
mortgage on the property. �inb atio rovi� u� Id h
�e n o ate a
p , g mount of
$78,056 left on the property of which the son's share would have been$39,028. Therefore, the net value of the
gift to the donor's son ins 2002 would be$55,972.
Form S86-A(1-1994) Catalog Number 20810W page publish.no.irs.gov Department of the Treasury-Intemal Revenue Service
Page 2
11/20/2014 4 : 13:09 PM —0600 IRS PAGE 5 OF 20
Farm$86-Q Schedule number or exhibit
(Rev.January 1994) EXPLANATION OF ITEMS Total annual exclusions
Name oftaxpayer Tax Identification Number YearlPeriod ended
Gudlaug B. Olafsson 206-56-3412 2002
Total annual exclusions
Item# Description Returned/Assessed Corrected
New Annuai Exclusion 0 10,000
Total of these Items 10,000
Shown on Return p
Change to Schedule 10,000
The total amount of a donors taxable gifts in any calendar year is reduced by the amount of the annual
exclusion available for gifts to each donee in that year. IRC section 2503(b}
DRAFT REP� RT
Farm gss-Q(1-1994) Catalog Number 20810W page publish.no.irs.gov Department of the Treasury-Intemal Revenue Service
Page 3
11J20/2014 4 :13:09 PM —0600 IftS PAGE 6 OF 20
Department ofthe Treasury-internal Revenue Service Date Received by
Waiver of Restrictions on Assessment and Collection Internal Revenue Service
Form$90 of Deficiency and Acceptance of Overassessment -
(November 2014) Estate, Gift, and Generation -Ski m Transfer Tax
Pp� 9
(Please see the instructions on the back of this form)
Part 1 -Consent to Assessment and Acceptance of Overassessment
I consent to the immediate assessment and collection of any deficiencies (increase in tax and penalties)and accept any
overassessment(decrease in tax and penalties)shown below, plus any interest provided by law. I understand that by my
signing this waiver, a petition to the United States Tax Court may not be made, unless additional deficiencies are
determined.
Date of Death or Period Ending
2002
Item Increase Decrease
Tax �� ��
Penalty $Q $0
Total ��
$0
If the estate is required to file, with the Internal Revenue Service, evidence of payment of estate, inheritance, legacy,
succession, or generation-sldpping transfer taxes to any State or the District of Columbia, I understand that such
evidence must be filed by or the deduction for these taxes will not be allowed. I also agree to the assessment
and collection of the increase in estate tax and penalties of$ based on the disallowed deduction, plus interest
figured to the 30th day after , or until this increase is assessed, whichever is earlier.
DRAFT REP� RT
Estate of
Executor or Administrator
Name Nell W. Yahtl Signature Date
Address
Executor or Administrator
Name Signature Date
Address
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Catalog Number 16949S www.irs.gov Form 890 (Rev.11-2014)
11/20/2014 4 : 13:09 PM —0600 IRS PAGE 7 OF 20
Page 2
Part 2-Applicable Credit Agreement
I agree to the increase or decrease in the total allowed Applicable Credit by the amount shown below.
Increase Decrease
Applicable Credit $9,633 $0.00
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Part 3-Gift Tax Marital Deduction
I agree to the increase or decrease in the usage of the gift tax marital deduction by the amount shown below.
Increase Decrease
Marital Deduction $0.00 $0.00
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Instructions for Fo 0, iv o ' i o s t ction of Deficiency
and Acceptance of O er s n te, ' ti i ing Transfer Tax
Consent to Assessment A ep ce Over ses e
If you consent to the assessment of the deficiencies shown in Part 1 of this form, please sign the agreement under Part 1
and return the form to limit any interest charge and expedite the adjustment to your account.Your consent will not prevent
a claim for refund from being filed(after the tax has been paid}if you later believe it is warranted, nor prevent us from later
determining that additional tax is owed, nor extend the time provided by law for either action.
If a claim is later filed and the Service disallows it, a suit for refund may be filed in a United States District Court or in the
United States Court of Federal Glaims, but a petition may not be filed with the United States Tax Court.
We will consider this waiver a valid claim for refund or credit of any overpayment due resulting from any decrease in tax
and penalties determined by the Internal Revenue Service, shown on the front of this form, provided Part 1 of this form is
signed and filed within the period established by law for making such a claim.
Applicable Credit Agreement
If you agree with the increase or decrease of the allowed credit shown in Part 2 of this form, please sign the agreement
under Part 2 and return the form.
Marital Deduction Agreement
If you agree with the increase or decrease in the usage of the gift tax marital deduction by the amount shown in Part 3 of
this form, please sign the agreement under Part 3 and return the form.
Signature Instructions
If the executor or administrator is a corporation, the waiver should be signed with the corporate name, followed by the
signatures and titles of the corporate officers authorized to sign. An attorney or agent may sign this waiver provided the
action is specifically authorized by a power of attorney which, if not previously filed, must accompany this form.
Catalog Number 16949S www.irs.gov Form 890 (Rev.11-2014)
11/20I2014 4 :13:09 PM -0600 IRS PAGE 8 QF 20
Report of Gift Tax Examination
Donor Social Security Number Date of Gift
Gudlaug B. Olafsson 206-56-3412 2005
Shown on Return/
As Prevlously As Corrected
Assessed
1. Total value of gifts of donor 0 62,000
2. Amount of gifts attributable to spouse � �
3. Gifts of donor less attributable to spouse 0 62,000
4. Gifts of spouse to be included 0 0
5. Total gifts(Lines 3+4J 0 62,000
6. Total annual exclusions 0 11,000
7. Total included amount of gifts(�ine 5-6) 0 51,000
8. Gift to spouse with MD claim 0 0
9. Exclusions attributable to gifts on Line 8 0 0
10. Marital deduction(Line 8-9) 0 0
11. Charitablededuction(netofexclusions) 0 0
12. Total deductions(Lrnes l0+11) 0 0
13. Tentative taxable gifts(tine 7-92) � 51,000
14. GST taxes payable � �
15. Taxable gifts for period(Lines 13+14) 0 51,000
16. Total taxable gifts for prior periods 0 45,972
17. Total taxable gifts 0 96,972
18. Tax computed on Line 1 0 22,952
19_ Tax computed on Line 16 0 9,633
20. Total tax payabie on taxable gifts 0 13,319
21. Unified credit from Table B 345,800 345,800
22. Unified credit for prior periods 0 9,633
23. Balance(�ine 2�-22) 345,800 336,167
24. 20%specific after 9/8(76 0 0
25. ealance(Lare 23-24) 345,800 336,167
26. Unified credit(Lessoro�Lines 20 or25) 0 13,319
27. Credit for foreign gift taxes 0 0
28. Total credRs(LrnesP6+27J 0 13,319
29. Balance(Line 20-28) 0 0
3�. Generation-skipping transfertax 0 0
31. Total tax(Lrnes 29+30) 0 0
32. Tax previously assessed(From Line 31) p
33. Total tax increase/decrease(Line 31-32) p
34. Penalties previously assessed p
35. Penalties as corrected code(s) 0
36. Net penalties increased/decreased(Line 35-34) 0
37. Increase/decrease in tax and penalties(Lrnes 33+36) p
Form 3233{��-20�2} Catalog Number 19401X publish.no.irs.gov Department of the Treasury-Intemal Revenue 5ervice
11/20/2014 4 : 13:09 PM —0600 IR� PAGE 9 OF 20
Form 88s-A Schedule number or exhibit
(Rev.January 1994) EXPLANATION OF ITEMS GiRs of Dmorwlo GST
(Schedule A Part1)
Name oftaxpayer Tax Identification Number YeadPeriod ended
Gudlaug B. Olafsson 206-56-3412 2005
Gifts of Donor w/o GST {Schedule A Part 1)
Item# Description Returned/Assessed Corrected
New Gift to Gudjon J. Olafsson a 62,000
Total of these Items 62,000
Shown on Return p
Change to Schedule 62,000
The donor and her son sold the jointly held property held in Camp Hiii, PA. The net proceeds from the sale of
the property were$124,d0a.The donor did not take her share of the proceeds, but allowed her son all of the
proceeds. Her share of the proceeds were$62,OQ0 of the net proceeds.The value of the gift to her son was
therefore$62,000 in 2005
DRAFT REP4RT
Form g86-Q(1-1994) Catalog Number 20810W paye publish.no.irs.gov Department of the Treasury-Intemal Revenue Service
Page 2
11/20/2014 4 : 13;09 PM —0600 IRS PAGE 10 OF 20
Form 8�6-Q Schedule number or exhibit
(Rev.January 1994) EXPLANATION OF ITEM5 Total annual exclusions
Name of taxpayer Tax Identification Number Year/Period ended
Gudlaug B. Olafsson 206-56-3412 2005
Total annual exclusions
Item# Description Returned/Assessed Corrected
New Annual Exclusion � 11,00�
Total of these Items 11,000
Shown on Return p
Change to Schedule 11,000
he total amount of a donor's taxable gifts in any calendar year is reduced by the amount of the annual
exclusion available for gifts to each donee in that year. IRC section 2503(b}
DRAFT REPORT
Form�Ss-Q{1-1994) Catalog Number 20810W page publish.no.irs.gov Department ofthe Treasury-Intemal Revenue Service
Page 3
11/20/2014 4 : 13; 09 PM —0600 IRS PAGE 11 OF 20
Department ofthe Treasury-Internal Revenue Service Date Received by
Waiver of Restrictions on Assessment and Collection �nternal Revenue Service
Form 89� of Deficiency and Acceptance of Overassessment -
(November 2014) Estate, Gift, and Generation -Ski m Transfer Tax
Pp� 9
(Please see the instructions on the back of this form)
Part 1 -Consent to Assessment and Acceptance of Overassessment
I consent to the immediate assessment and collection of any deficiencies{increase in tax and penalties)and accept any
overassessment(decrease in tax and penalties)shown below, plus any interest provided by law. I understand that by my
signing this waiver, a petition to the United States Ta�c Court may not be made, unless additional deficiencies are
determined.
Date of Death or Period Ending
2005
Item Increase Decrease
Tax $0 $0
Penalry $p $0
Total �Q $0
If the estate is required to file, with the Internal Revenue Service, evidence of payment of estate, inheritance, legacy,
succession, or generation-sldpping transfer taxes to any State or the District of Golumbia, I understand that such
evidence must be filed by or the deduction for these taxes will not be allowed. I also agree to the assessment
and collection of the increase in estate tax and penalties of$ based on the disallowed deduction, plus interest
figured to the 30th day after , or until this increase is assessed, whichever is earlier.
DRAFT REPC� RT
Estate of
Executor or Administrator
Name Neil W. Yahn Signature Date
Address
Executor or Administrator
Name Signature Date
Address
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Catalog Number 16949S www.irs.gov Form 8J0 (Rev.11-2014)
11/20I2014 4 ; 13:09 PM —0600 IRS PAGE 12 OF 20
Page 2
Part 2-Applicable Credit Agreement
I agree to the increase or decrease in the total allowed Applicable Credit by the amount shown below.
Increase Decrease
Applicable Credit $13,319 $0.00
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Part 3-Gift Tax Marital Deduction
I agree to the increase or decrease in the usage of the gift tax marital deduction by the amount shown below.
Increase Decrease
Marital Deduction $0.00 $0.00
Donor
Name Gudlaug B. Olafsson, Signature Date
206-56-3412
Address
Instructions for Fo 0, iv o � ti o s t ction of Deficiency
and Acceptance of O er s n s te, ' ti i ing Transfer Tax
Consent to Assessment A ep ce Over ses e
If you consent to the assessment of the deficiencies shown in Part 1 of this form, please sign the agreement under Part 1
and return the form to limit any interest charge and expedite the adjustment to your account.Your consent will not prevent
a claim for refund from being filed(after the tax has been paid)if you later believe it is warranted, nor prevent us from later
determining that additional tax is owed, nor extend the time provided by law for either action.
If a claim is later filed and the Service disallows it, a suit for refund may be filed in a United States District Court or in the
United States Court of Federal Claims, but a petition may not be filed with the United States Tax Court.
We will consider this waiver a valid claim for refund or credit of any overpayment due resulting from any decrease in tax
and penalties determined by the Internal Revenue Service, shown on the front of this form, provided Part 1 of this form is
signed and filed within the period established by law for making such a claim.
Applicable Gredit Agreement
If you agree with the increase or decrease of the allowed credit shown in Part 2 of this form, please sign the agreement
under Part 2 and return the form.
Marital Deduction Agreement
If you agree with the increase or decrease in the usage of the gift tax marital deduction by the amount shown in Part 3 of
this form, please sign the agreement under Part 3 and return the form.
Signature Instructions
If the executor or administrator is a corporation, the waiver should be signed with the corporate name, followed by the
signatures and titles of the corporate officers authorized to sign. An attorney or agent may sign this waiver provided the
action is specifically authorized by a power of attorney which, if not previously filed, must accompany this form.
Catalog Number 16949S www.irs.gov Farm 890 (Rev.11-2014)
11/20/2014 4 : 13:09 PM —0600 IRS PAGE 13 OF 20
Department of the Treasury- Internal Revenue Service
Report of Estate Tax Examination Changes
Form 1273
Estate of: Gudlaug B. Olafsson Social Security Number:206-56-3412 Date of death: 12/24/2008
Name of Person With Whom Findings were Discussed: Agreement Secured:
Neil W. Yahn, Executor Yes
1 Tentative Taxable Estate Shown on Return or Previously Adjusted 2,184,235
2 Increase/Decrease in Tentative Taxable Estate 76,834
3a Tentative Taxable Estate as Corrected(Line 1 plus/minus Line 2) 2,261,069
Shown on Return/
As Previously As Corrected
Assessed
3b State Death Tax Deduction 0 0
3c Taxable Estate as Corrected(Line 3a—Line 3b} 2,184,235 2,261,069
4 Adjusted Taxable Gifts 0 96,972
5 Total 2,184,235 2,358,041
6 Tentative Tax 863,706 941,918
7 Aggregate Gift Tax Payable (After Dec. 31, 1976) 0 0
8 Tax Before Unified Credit(Line 6—Line 7) 863,706 941,918
9a Basic Exclusion Amount 2,000,�00 2,OOO,Q00
9b Deceased Spousal Unused Exclusion(DSUE) 0 0
9c Applicable Exclusion Amount(Line 9a+Line 9b) 2,000,000 2,000,000
9d Applicable Credit Amount(from Table A usin Line 9c 780,80� 780,800
10 Adjustment to Unifie Cr 0 0
11 Allowable applicable t m 780,800 780,800
12 Tax Before SDTC(Line 8—Line 11) *Cannot be�Q 82,906 161,118
13 State Death Tax Credit � p
Tentatively Allowed
Submit Evidence by
14 Net Tax Post State Death Tax Credit(Line 12—Line 13) 82,906 161,118
15 Gift Tax Credit(Pre-1977 Gifts} 0 0
16 Foreign Death Tax Credit(Statutory) 0 0
17 Prior Transfer Credit 0 0
18 Foreign Death Tax Credit(Treaty)/Canadian Marital Credit 0 0
19 Total Credits{Sum of Lines 15 through 18) 0 0
20 Net Estate Tax Payable 82,906 161,118
21 Generation Skipping Transfer Taxes(Schedule R, Part 2, Line 12) p p
22 Increased Estate Tax (Section 4980A, Schedule S) 0 0
23 Total Federal Estate Tax(Sum of Lines 20 through 22) 82,906 161,118
24 Total Transfer Tax Previously Assessed. 82,906
25 Total Transfer Tax Increase/Decrease(Line 23—Line 24} 7g,2�2
26 Penalties Previously Assessed—Code(s): 27,359
27 Penalties as Corrected—Code(s):6651 47,024
28 Net Penalties Increase/Decrease(Line 27—Line 26) 19,665
29 Net Tax and Penalties Payable Increase/Decrease(Line 25+Line 28) 97,877
Signature: Date: 11/10/2014
Amy Panebianco
11I20/2014 4 : 13:09 PM —0600 IRS PAGE 14 OF 20
Department of the Treasury- Internal Revenue Service
Line Adjustment-Estate Tax
Form 6180
Estate of:Gudlaug B. Olafsson Social Security Number:206-56-3412 Date of Death:12/24/2008
Shown on Returnl
As Previousty Changed As Corrected
Assessed
1 Schedule A, Real Estate 1,111,837 75,894 1,187,731
2 Schedule B, Stocks and Bonds 0 0 0
3 Schedule C, Mortgages, Notes, and Cash 95,657 0 95,657
4 Schedule D, Insurance on the Decedent's Life 0 0 0
5 Schedule E, Joint Owned Property 0 0 0
6 Schedule F, Other Miscellaneous Property 21,842 0 21,842
7 Schedule G, Transfers During DecedenYs Life 444,826 940 445,766
8 Schedule H, Powers of Appointment Q 0 0
9 Schedule I, Annuities 650,842 0 650,842
10 Gross Estate 2,325,004 76,834 2,401,838
11 Schedule U, Qualified Conservation Easement Exclusion 0 0 0
12 Gross Estate less exc si 25, 76,834 2,401,838
13 Schedule J, Funeral a d ini ative pens s ,7 9 0 140,769
14 Schedule K, Debts of Decedent 0 0 0
15 Schedule K, Mortgages and Liens 0 0 0
16 Total of Schedules J and K(Lines 13, 14, +15) 140,769 0 140,769
17 Allowable deductions from Schedules J and K 140,769 0 140,769
18 Schedule L, Net Losses During Administration 0 0 0
19 Schedule L, Expenses and Property Not Subject to Claims 0 0 0
20 Total(Lines 17, 18, +19} 140,769 0 140,769
21 Schedule M, Marital Deduction 0 0 0
22 Schedule O, Charitable Bequests 0 0 0
23 ESOP Deduction 0 0 0
24 Schedule T, QFOB Deductions p Q 0
25 Total Allowable Deductions(Lines 20, 21, 22, 23, +24) 140,769 0 140,769
26 Tentative Taxable Estate(Line 12-25) 2,184,235 76,834 2,261,069
11/20/2014 4 : 13;09 PM —0600 IRS PAGE 15 OF 20
Form 886-Q Schedule num6er or exhibit
(Rev.January 1994) EXPLANATI�N OF ITEMS A - Real Estate
Name of taxpayer Tax Identification Number YeadPeriod ended
Gudlaug B. Olafsson 206-56-3412 12/24l2008
A - Real Estate
Item# Description Returned/Assessed Corrected
1 Property located at Laugarasvegur, 20, Reyjavki 981,857 1,057,751
Total of these Items 981,857 1,057,751
Shown on Return 981,857
Change to Schedule 75,894
The real property indicated above has been adjusted to its fair market value of the valuation date based upon
a sale of the property in an arm's-length transaction within a reasonable time of the valuation date. Section
20.2�31-1(b)ofthe Federal Estate Tax Regulations.
DRAFT REP� RT
Form$$s-Q(1-1994) Catalog Number 20810W Page publish.no.irs.gov Department ofthe Treasury-Intemal Revenue Service
Page 3
11/20/2014 4 ; 13:09 PM —0600 IRS PAGE 16 OF 20
Form�86-Q Schedule number or exhibit
(Rev.January 1994) EXPLANATION OF ITEMS Adjusted Taxable Gifts
Name oftaxpayer Ta�c Identification Number YeaNPeriod ended
Gudlaug B. Olafsson 206-56-3412 12/24I2008
Adjusted Taxable Gifts
Item# Description Returned/Assessed Corrected
New Gift of Proceeds from sale of property located at 2331 CHESTNUT 0 96,972
Total of these Items 0 96,972
Shown on Return �
Change to Schedule 96 9�2
The amount of adjusted taxable gifts has been adjusted to reflect the fair market value of the above gift(s)
as of the date of such gift.The term"adjusted taxable gifts"means the total amount of the taxable gifts
(within the meaning of Code section 2503) made by the decedent after December 31, 1976,other than gifts which
ere includible in the gross estate of the decedent. Code section 2001(b).The amount of the adjusted taxable
gifts has been determined as follows:
In September of 2002, the donor tiitled her propery located in Camp Hill in the name of herself and her son, ,
Gudjon J. Olafsson asjoint tenants with right of survivorship. The property had an assessed value of$199,280
at the time of the transfer In 2005, the property sold for$190,000. No appraisals have been done on the
property. A sale can be use t � e ma . i h , ., Est,
(2013)TC Memo 2013-27, IA 7, 05� 1��; B �, d�el E. Est v. Com., (1970,
CA5}25 AFTR 2d 70-1610, 1 , 7 UST 126�3 �f ! TC
¶ 1lk�fo�96�9'�PH TC
TCM ' � , M¶69091, 28 CCH
497(e); Max Shlensky, (Blanche Siegel) (1977)TC Memo 1977-148, PH TCM P 77,148; Keitel, Frederick J. Est,
(1990}TC Memo 1990-416, PH TCM¶90416, 60 CCH TCM 425 and
Levy v US, 402 Fed.Appx. 979, 2010 WL 4942108(C.A.5(Tex.)), 106 A.F.T.R.2d 2010-7205, 2010-2 USTC P 60,608.
The value of the property at the time it was made joint with the decedenYs son is$19�,000. There was a
mortgage on the property. Based upon the information provided, there would have been a mortgate amount of
$78,056 left on the property of which the son's share would have been$39,028. Therefore, the net value of the
gift to the donor's son ins 2002 would be$55,972.
The donor and her son sold the jointly held property held in Camp Hill, PA.The net proceeds from the sale of
the property were$124,000.The donor did not take her share of the proceeds, but allowed her son all of the
proceeds. Her share of the proceeds were$62,000 of the net proceeds.The value of the gift to her son was
therefore$62,000 in 2005
Form$86-Q(1-1994) Catalog Number 20810W paye pu6lish.no.irs.gov Department of the Treasury-Intemal Revenue Service
Page 4
11/20/2014 4 :13;09 PM —0600 IRS PAGE 17 OF 20
Form$$s-A Schedule number a exhibit
(Rev.January 1994} EXPLANATION �F ITEMS G-Transfers During Life
Name of taxpayer Tax Identiflcation Number Year/Period ended
Gudlaug B. O�afsson 206-56-3412 12/24/2008
G -Transfers During Life
Item# Description ReturnedJAssessed Corrected
New Accrued Dividends for PIMCO FDS PAC Invt MGMT � 203
New Dividend accrual for shares of American Century Govt Income Tr 0 16
5 985 shares ISHARES Tr: 42,463 42,657
6 494 shares ISHARES Tr 21,277 21,506
7 45�shares ISHARES Tr: 38,997 39,295
Total of these Items 102,737 103,677
Shown on Return 102,737
Change to Schedule 940
Dividends which are payable to the decedent or his/her estate by reason of the fact that on or before the date
of the decedenYs death he/she was a stockholder of record(but which have not been collected at death)
constitute a part of the gros t a e . . -1( .
Where a dividend is declare�a h f s � �
k befo�e the ec
���
th� bl o fockholders of
record on a date after his/her death and the stock is selling"ex-dividend"on the date of the decedent's
death,the amount of the dividend is added to the ex-dividend quotation in determining the fair market value
of the stock as of the date of the decedenYs death.Treas. Reg.20.2031-2{i); Rev. Rul. 54-399, 1954-2
Cum.Bull. 279.
Form$$s-Q(1-1994) Catalog Number 20810W aage publish.no.irs.gov Department of the Treasury-Internai Revenue Service
Page 5
11/20/2014 4 :13:09 PM —0600 IRS PAGE 18 OF 20
Form g86-Q Schedule number or exhibit
{Rev.January 1994) EXPLANATION OF ITEMS Penalty 6651-Fallure to
FileiFailure to Pey
Name of taxpayer Ta�c Identification Number
Year/Period ended
Gudlaug B. Olafsson 206-56-3412 12/24/2008
Penalty 6651 - Failure to File/Failure to Pay
Item# Description Returned/Assessed
Corrected
Penalty Failure to File and to Pay Penalty 27,359
47,024
Total of these Items 27,359
47,024
Shown on Return
27,359
Change to Schedule
19,665
The amount of the addition to the tax under Code section 6651(a}(1)shall be reduced by the amount of the
additional Code section 6651(a)(2)for any month to which an addition to tax applies under both. Code section
6651(c)(1);Treas. Reg. 301.6651-1(a)(1).
DRAFT
REP� RT
Form 886-Q(1-1994} Catalog Number 2081DW page publish.no.irs.gov Department ofthe Treasury-Internai Revenue Service
Page 6
11/20/2014 4 ; 13:09 PM —0600 IRS
PAGE 19 OF 20
Department ofthe Treasury-Internai Revenue Service Date Received by
Form 89� Waiver of Restrictions on Assessment and Collection Internal Revenue Service
(November 2014) of Deficiency and Acceptance of Overassessment -
Estate, Gift, and Generation -Skipping Transfer Tax
(Please see the instructions on the back af this form)
Part 1 -Consent to Assessment and Acceptance of Overassessment
I consent to the immediate assessment and collection of any deficiencies (increase in tax and penalties)and accept any
overassessment(decrease in tax and penalties)shown below, plus any interest provided by law. I understand that by my
signing this waiver, a petition to the United States Tax Court may not be made, unless additional deficiencies are
determined.
Date of Death or Period Ending
12/24/2008
Item Increase Decrease
Tax
Penalry $78,212 $0
6651 $19,665
$0
Total
$97,877 $0
If the estate is required to file, with the Internal Revenue Service, evidence of payment of estate, inheritance, legacy,
succession, or generation-s4dpping transfer taxes to any State or the District of Columbia, I understand that such
evidence must be filed by , or the deduction for these taxes will not be allowed. I also agree to the assessment
and collection of the increase in estate tax and penalties of$ based on the disallowed deduction, plus interest
figured to the 30th day after , or until this increase is assessed, whichever is earlier.
DRAFT
REPC� R
T
Estate of Gudlaug B. Olafsson, 206-56-3412
Executor or Administrator
Name Neil W. Yahn Signature
Date
Address
Executor or Administrator
Name Signature Date
Address
Donor
Name Signature Date
Address
Catalog Number 16949S www.irs.gov Form$9� (Rev.11-2014)
11/20/2014 4 ;13;09 PM —0600 IRS PAGE 20 OF 20
Page 2
Part 2-Applicable Credit Agreement
I agree to the increase or decrease in the total allowed Applicable Credit by the amount shown below.
Increase Decrease
Applicable Credit
Donor
Name Signature Date
Address
Part 3-Gift Tax Marital Deduction
I agree to the increase or decrease in the usage of the gift tax marital deduction by the amount shown below.
Increase Decrease
Marital Deduction
Donor
Name Signature Date
Address
Instructions for Fo 0, iv o ' i o s t ction of Deficiency
and Acceptance of O er s n s te, ' ti i ing Transfer Tax
Consent to Assessment A ep ce Over ses e
If you consent to the assessment of the deficiencies shown in Part 1 of this form, please sign the agreement under Part 1
and return the form to limit any interest charge and expedite the adjustment to your account.Your consent will not prevent
a claim for refund from being filed{after the tax has been paid}if you later believe it is warranted, nor prevent us from later
determining that additional tax is owed, nor extend the time provided by law for either action.
If a claim is later filed and the Service disallows it, a suit for refund may be filed in a United States District Court or in the
United States Court of Federal Claims, but a petition may not be filed with the United States Tax Court.
We will consider this waiver a valid claim for refund or credit of any overpayment due resulting from any decrease in tax
and penalties determined by the Internal Revenue Service, shown on the front of this form, provided Part 1 of this form is
signed and filed within the period established by law for making such a claim.
Applicable Credit Agreement
If you agree with the increase or decrease of the allowed credit shown in Part 2 of this form, please sign the agreement
under Part 2 and return the form.
Marital Deduction Agreement
If you agree with the increase or decrease in the usage of the gift tax marital deduction by the amount shown in Part 3 of
this form, please sign the agreement under Part 3 and return the form.
Signature Instructions
If the executor or administrator is a corporation,the waiver should be signed with the corporate name, followed by the
signatures and titles of the corporate officers authorized to sign. An attorney or agent may sign this waiver provided the
action is specifically authorized by a power of attorney which, if not previously filed, must accompany this form.
Catalog Number 16949S www.irs.gov Form 890 {Rev.11-2014)
L R
� DEPARTMENT OF THE TREASURY
z �� � tNTERNAL REVENUE SERVICE
' � Washington,D.C.2p224
vsC
SMALL BUSINESS/SELF-EMPLOYED DIYISION
Date: May 29, 20'I4
Neil W. Yahn
PO Box 650
Hershey, Pennsylvania 17033
Dear Mr. Yahn,
Per your request, enclosed please find a draft copy of a report showing the adjustments to fhe
schedule A, Schedule G (for accrued dividends) and for the adjusted taxable gifts. Per my
phane message to you, if the estate has paid any state inherifance taxes or has any foreign
death tax credit that needs to be ciaimed, please let me knaw so ( can take these into account.
!f the estate agrees to the adjustments, the estate is also entitled to a deduction for any in#erest
accrued on the deficiency. I have not included that calculation in the computation as you have
nof indicated agreement.
Please review the enclosed report and let me know by June 12, 2014 hovv you wish to proceed.
If you agree thaf the property located at 233i Chestnu#St., Camp Hilf, PA was ni;.•�d, ! �F�il! n�nd
ior�you tc.fiI•� a �orn� 709 with mE. My phone number is 724-720-2019 and my address is
Internat Revenue Service
230 Executive Dr.
Suite 1p0
Cranberry Township, PA 16066
Shauld you have any questions, please do not hesita#e to call me.
Sincer�ely,
, ��-�-r�-�-C.�"i�'i't C�
my Pa ebianco
Attorney(Estate Tax}
Enc:
Report
Pub(ication 3498
Neil Warner Yahn,Esquire
Attorney I.D.No. 82278
James Smith Dietterick&Connelly,LLP
P.O.Box 650
Hershey,PA 17033
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN�' • No. 21 - 10 - 0973
ESTATE OF GUOLAUG BRYNJA
GUOJONSDOTTIR, deceased ,
CERTIFICATE OF SERVICE
AND NOW, thi�day of December,2014, I,Neil W. Yahn, Esquire, do hereby certify
that I served a h-ue and correct copy of the foregoing Motion to Compromise upon the following
below-named individuals by depositing the same in the U.S. Mail,postage pre-paid at Hershey,
Dauphin County, Pennsylvania and/or electronically:
Gudjon J. Olafsson Bryndis Gu�jonsdottir Brynja Gu�jonsdottir
52 Boatswain Drive Reynihli� 4 20
Berlin, MD 21811 IS-105 Reykjavik IS-104 Reykjavik
Asa B. Oates Olafur K. Olafsson4 Halldor Reynir Halldorsson
121 Mapleton Blvd 145 Taylor Street, Apt 608 Adalstraeti 6
Harrisburg, PA 17112 San Francisco, CA 94102 IS-101 Reykjavik
,
�. ���
Neil W. a , Esquire
�
�
,
r,<
4 Petitioner acknowledges significant hurdles in serving Olafur= .Olafsso and will confirm delivery whether
electronically or United States First-Class Mail, Certified Retu ece' equested.