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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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