Estate of Bonnie J. Liston Harden, Deceased, David J. Kotler, Executor - Page 7

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          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 pay             








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