- 7 - investment, David asked Rory to lend petitioner $300,000. Rory liquidated the Joint Tenancy Account and lent $300,000 to petitioner. Petitioner then invested the $300,000 in USM. On April 24, 1989, David executed, on behalf of petitioner, a promissory note in favor of Rory. The note obligated petitioner to repay, on April 24, 1994, the $300,000 and 10 percent interest compounded annually. The USM investment initially performed as expected. USM made the first two payments on schedule. In October of 1989, however, the payments stopped. In November of 1989, David conducted additional investigations of USM and concluded that the business was a sham, and that petitioner's funds had not been invested. In December of 1989, David demanded a $300,000 refund. Soon thereafter, David learned that the USM representative had embezzled the $300,000, and that USM had filed for bankruptcy protection. Petitioner did not recover its $300,000 investment. III. Filing of Estate Tax Return On October 23, 1989, petitioner mailed a Form 4768 (Application for Extension of Time to File U.S. Estate (and Generation-Skipping Transfer) Tax Return and/or Pay Estate (and Generation-Skipping Transfer) Tax(es)). On the form, petitioner requested an extension of time, until April 28, 1990, to file a return and an extension of time, until October 28, 1990, to payPage: 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