Edward Fridovich, Transferee - Page 4




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          $10,925,101.10 total unpaid estate tax liability of the estate),            
          unless the statute of limitations or the doctrine of laches bars            
          the assessment of this liability.  Thus, following concessions by           
          both parties, the issue to be decided is whether the statute of             
          limitations (or alternatively, the doctrine of laches) bars                 
          respondent from assessment and collection of the $1,118,621                 
          transferee liability against petitioner.                                    
               The stipulation of facts and the attached exhibits are                 
          incorporated herein.  The stipulated facts are hereby found.                
               At the time the petition was filed, petitioner resided in Fort         
          Lauderdale, Florida.                                                        
                                     Background                                       
               On December 4, 1981, Martin Fridovich died testate.                    
          Petitioner served as personal representative of the estate until            
          June 11, 1984, when he was replaced by his brother, Anthony                 
          Fridovich.                                                                  
          The Estate Tax Return                                                       
               On September 21, 1982, the estate filed a Form 706, U.S.               
          Estate Tax Return, reflecting $3,883,147.43 in tax due; it paid             
          $12,426.07.  Pursuant to section 6166, the estate elected to defer          
          payment of the balance ($3,870,721.36) for 5 years and to                   
          thereafter pay the balance in 10 annual installments of $387,072.14         
          each.                                                                       








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