Estate of Houshang Mehrafsar, Deceased, Bank of America, NT & SA, Special Administrator - Page 7

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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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