- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011