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Section 2057 [sic] (b)(7)(B)(v), but cannot, at
this time, determine which portion of the estate
is to be treated as "qualified terminable
interest property."
Along with the application for an extension of time to
file, petitioner's attorney sent a payment of estate tax in
the amount of $156,424 and requested an extension of time
to pay any additional amount of estate tax for the
following reason:
The amount of estate taxes can not [sic] be
determined because the size of the gross estate
is unascertainable (for the reasons set forth
above under "Extension of Time to File"), and
the executor's election to treat property passing
to the surviving spouse as qualified terminable
interest property cannot be made. Nevertheless,
a payment of $156,424 against the amount of
estate taxes estimated to be due is paid with
this application.
Petitioner's attorney did not explain how the estate tax
payment of $156,424 was computed.
On May 22, 1989, the executor filed the petitioner's
United States Estate (and Generation-Skipping Transfer)
Tax Return on IRS Form 706. According to the return, the
decedent and Mrs. Rapp owned community property worth
$11,255,444.12 at the time of the decedent's death. The
return reports that the decedent's total gross estate,
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