Estate of Bonnie J. Liston Harden, Deceased, David J. Kotler, Executor - Page 3

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               6.  Whether petitioner, pursuant to section 6651(a)(1), is             
          liable for an addition to tax for failing to file its estate tax            
          return in a timely manner.  We hold that petitioner is liable.              


                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  At           
          the time of her death, on January 28, 1989, Bonnie Harden resided           
          in South Lake Tahoe, California.  At the time the petition was              
          filed, the executor resided in Los Angeles, California.                     
               Earl and Bonnie Harden were married and lived together in              
          South Lake Tahoe, California, until Earl's death in February of             
          1985.  Previously Earl and Bonnie had both retired from the                 
          business of selling and installing countertops.  Although Earl              
          had severe physical limitations (i.e., he was confined to a                 
          wheelchair) as a result of a fall in 1981, he continued to make             
          decisions independently.  Earl and Bonnie had one adult son,                
          Rory.                                                                       
               In 1981, Earl and Bonnie met David Kotler, and they quickly            
          became close friends.  David was an accountant.  He graduated in            
          1976 from Long Island University, C.W. Post School of                       
          Professional Accountancy, in New York.  After graduating, he                
          moved to California.  During the course of his career, he was               
          employed by accounting firms and defense contractors.                       








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