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23, 1988, but before September 1, 1989, as is maintained by
Mehrafsar, that the IRS had granted only a 6-month extension of
time to file the estate tax return. Mehrafsar's testimony
otherwise is incredible.
On August 1, 1989, after Mehrafsar had retained new legal
counsel, Mehrafsar wrote a letter to the IRS in which he
explained that he had been "approved" for an extension of time to
file the estate tax return but was unable to locate his copy of
the extension. The letter continues with Mehrafsar requesting
"another" copy of the extension. It is clear from the language
used in this letter that Mehrafsar learned prior to August 1,
1989, that the IRS had approved only a 6-month extension. If, as
he claims, Mehrafsar was not aware until sometime in September
1989 that the IRS had granted only a 6-month extension, we
question whether he would have written a letter in August 1989
explaining that he had been "approved" for an extension but was
unable to locate his copy of the approval. This is especially so
in light of Mehrafsar's testimony that, at the time he signed the
Form 4768, he was unaware that extension requests were subject to
"approval" by the IRS.
A question remains, however, as to precisely when Mehrafsar
learned that he had received only a 6-month extension of time to
file the estate tax return. The record is less than explicit on
this matter, but a finding is necessary in order to determine the
extent to which an addition to tax imposed by section 6651(a)(1)
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