Estate of Joseph G. Maltaman, Deceased, Paul J. Constantino, Special Administrator - Page 8

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          file timely would be imposed on the estate because it appeared to           
          him that the estimated tax payment that had been made when                  
          extension of the initial due date was requested exceeded the                
          amount of estate tax due from the estate.  After the second                 
          extension request was denied, Mr. Constantino did not ask Mr.               
          Belotz to file petitioner's estate tax return as quickly as                 
          possible, nor did Mr. Constantino do any research concerning the            
          consequences of filing untimely.                                            
               At the time that the second extension request was denied,              
          Mr. Belotz had sufficient information concerning assets                     
          includable in decedent's estate to prepare the estate tax return,           
          but lacked information concerning its expenses, which he sought             
          to obtain from Mr. Constantino.  At that time, it did not occur             
          to Mr. Belotz to file a return based on the information then                
          available to him.                                                           
               In a letter to Mr. Blum dated October 1, 1991, Mr. Belotz              
          complained that Mr. Constantino "has been uncooperative in                  
          submitting the necessary information to prepare the federal and             
          state tax forms that are overdue."  In a letter to Mr.                      
          Constantino dated October 14, 1991, Mr. Belotz wrote that he had            
          not received the necessary information from Mr. Constantino and             
          insisted that Mr. Constantino contact him.  Mr. Constantino                 
          provided information on expenses at the end of October 1991.                
          During December 1991, Mr. Belotz requested further information              
          from Messrs. Constantino and Blum for preparation of petitioner's           




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