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action by decedent's executor against Harry Williamson was begun
on January 21, 1988.
Because decedent died on June 30, 1987, the Form 706, United
States Estate Tax Return, was originally due to be filed on or
before March 30, 1988. Given the dispute between decedent's
estate and her surviving husband and the pending litigation
regarding decedent's assets, decedent's estate, petitioner
herein, filed a request for extension of time (Form 4768) in
which to file its Federal estate tax return on January 29, 1988.
A statement was attached to the request for extension of time,
which explained that because of the pending dispute between
decedent's estate and Harry Williamson, the executor had been
unable to identify, inventory, or marshal the assets of
decedent's estate. The extension of time requested was until
September 30, 1988, and this request was granted by respondent.
The Federal estate tax return was duly filed timely by
petitioner on September 30, 1988. To that return were attached,
inter alia, a copy of decedent's last will and testament; a copy
of the California probate court order appointing the executor of
decedent's estate; and a copy of the Form 4768, which was
petitioner's request for an extension of time to file a Federal
estate tax return, and which included an explanation on that
extension request form--that because of the ongoing dispute
between decedent's estate and Harry Williamson, it was impossible
at the time to identify or value the assets that were returnable
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