Estate of Houshang Mehrafsar, Deceased, Bank of America, NT & SA, Special Administrator - Page 3

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          Warren died in 1992.  John Hanrahan (Hanrahan) was decedent's               
          attorney.                                                                   
               Upon assuming his duties as special administrator, Mehrafsar           
          was aware of the requirement to file a Federal estate tax return            
          for decedent's estate within 9-months of decedent's date of                 
          death.  Mehrafsar began undertaking his responsibilities as                 
          special administrator with the assistance of Hanrahan and Warren.           
          This was consistent with decedent's prior requests.  In June or             
          July 1988, however, Hanrahan died, and Mehrafsar retained the               
          services of a local law firm, Hastings, Blanchard, Weiler &                 
          Kennedy (Hastings), for guidance in proceeding with his duties as           
          special administrator.  Jack A. Crickard (Crickard) had an                  
          association with Hastings and was one of Hastings' attorneys who            
          assisted Mehrafsar in matters pertaining to the estate.                     
               Acting on the advice of Hastings, Mehrafsar filed an                   
          application for an extension of time to file (Form 4768) the                
          estate tax return.  The application was prepared by Hastings,               
          signed by Mehrafsar in Hastings' office, and requested a 12-month           
          extension, until September 26, 1989.  Mehrafsar did not attach an           
          estimated tax payment to the application.  In addition to                   
          providing Mehrafsar's address, the application contained a                  
          statement that the value of the estate "cannot be estimated due             
          to estate litigation".                                                      
               The Internal Revenue Service (IRS) granted Mehrafsar a 6-              
          month extension, until March 26, 1989.  The approval is provided            




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