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Application for Extension of Time to File U.S. Estate Tax Return
and/or Pay Estate Tax. The address shown on the Form 4768 was
that of Nicholas. The United States Estate Tax Return, Form 706,
was subsequently filed, signed by petitioner, and dated
November 12, 1985. The return included a schedule of assets and
deductions and listed the value of the total gross estate of the
decedent as $544,856. Included in the return was a schedule of
annuities that listed the value of the decedent's profit sharing
plan and employee's money purchase plan as $260,715.00. After
deductions, the amount listed as "Bequest, etc., to Surviving
Spouse" was $530,867. The address shown on the estate tax return
included zip code 95864. Sometime during 1985, petitioner's home
zip code was changed by the U.S. Postal Service from 95825 to
95864.
On January 10, 1986, the Superior Court of the State of
California issued an Order conveying the decedent's community
property to petitioner. Petitioner represented the estate
herself, acting in "Pro Per". On March 20, 1986, the Internal
Revenue Service (IRS) mailed to Nicholas an Estate Tax Closing
Letter for the decedent's estate showing zero estate tax due.
The letter was addressed to petitioner, shown as "Anna Lee Locke,
Executrix". Nicholas sent the letter to petitioner with a note
stating, "This means that you are through as far as the Internal
Revenue Service is concerned regarding the estate."
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