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New York Section 6166 Computations

Last Updated: 05 September 2014

1. New York 6166(a) - Underpayment of non-deferred tax - Mar-11-2011 original return computation. The return is filed on the 6-month extended due date of Mar-11-2011. The state death tax deduction is limited to the total New York tax paid at the time the return is filed. Interest is not allowed as a deduction in either computation because the estate did not claim the deduction, and because the Federal return has not been accepted as filed. 

2. New York 6166(a) - Underpayment of non-deferred tax - Apr-19-2011 Campus bill for interest. Interest is computed through Apr-19-2011 for both Federal and New York purposes on the assumption here that both interest amounts will be paid simultaneously. Since interest is still not being allowed as a deduction in this computation, it does not matter that we compute the additional New York interest, because the overall New York tax payments remain the same (and thus, also the net Federal estate tax). The requested Federal interest payment of $4,020.69 is the amount that would have been billed by Cincinnati Campus in any event.

3. New York 6166(a) - Underpayment of non-deferred tax - Sep-11-2011 first anniversary date. Federal and New York interest is computed through the first anniversary date of Sep-11-2011. Interest is not allowed as a deduction. The state death tax deduction remains the same. The IRS has begun a field examination of the estate tax return.

4. New York 6166(a) - Underpayment of non-deferred tax - Sep-11-2012 second anniversary date. Federal and New York interest is computed through the second anniversary date of Sep-11-2012. Interest is not allowed as a deduction. The state death tax deduction remains the same. The IRS field examination is still open.

5. New York 6166(a) - Underpayment of non-deferred tax - Jun-05-2013 IRS field exam deficiency computation. All New York interest and the deductible Federal interest accrued on the respective payment dates of Jun-05-2013 is allowed as a deduction in computing the estate tax. Additional New York estate tax is paid, and the corresponding state death tax deduction on the Federal return is increased. The Federal and New York estate tax and interest are interrelated.

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