9
return for audit may be a reasonably informed one. Estate of
Frane v. Commissioner, 98 T.C. 341, 355 (1992), affd. in part and
revd. in part 998 F.2d 567 (8th Cir. 1993).
In this case, the application for extension of time to file
the estate tax return included a written statement as to the
reasons for requesting the delay: that because of a dispute
between decedent's estate and her surviving husband, the estate
was unable to list and value the items of the estate that should
be returned. When the Federal estate tax return of decedent was
filed on September 30, 1988, those facts were still unknown, but
that extension of time form, with its explanatory statement, was
attached to the return. We think this extension of time (with
explanation), which was adhered to by petitioner, was a
"statement attached to the return" and thus falls within the
language of section 6501(e)(2). It gave adequate notification to
respondent of petitioner's failure to itemize and value specific
items of decedent's gross estate that concededly should be
returned for estate tax purposes, and the reasons therefor. The
estate tax return itself said nothing to the contrary. In fact,
as the stipulated facts show, petitioner did not find out the
items of the gross estate, and their value, which properly formed
part of decedent's gross estate, until September 19, 1991.
Under these circumstances, we agree with petitioner that the
general 3-year statute of limitations applies in this case rather
than the 6-year statute of limitations provided by section
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