- 4 - experience in preparing Federal estate tax returns. Mr. Blum asked Alfred Belotz, a public accountant since 1951, to prepare the income tax return required in connection with the guardianship proceeding, and Mr. Blum suggested to Mr. Constantino that Mr. Belotz also prepare petitioner's estate tax return. Mr. Blum had known Mr. Belotz for 40 years and had previously retained him to perform work with respect to estates for which Mr. Blum was attorney. On January 17, 1991, Messrs. Blum, Belotz, and Constantino met, and Mr. Constantino agreed at that time to engage Mr. Belotz to prepare the estate's Federal tax returns. Mr. Constantino was made aware of the due date of petitioner's estate tax return, which was February 28, 1991 (initial due date), and that due date was discussed at the meeting. Because of the difficulties associated with identifying decedent's assets, it was decided to seek an extension of the time for filing petitioner's estate tax return. Messrs. Constantino and Blum provided Mr. Belotz with information concerning the assets includable in decedent's estate and the estate's deductible expenses, from which the estate's Federal estate tax liability could be estimated. Mr. Belotz prepared a Form 4768, Application for Extension of Time to File U.S. Estate (and Generation-Skipping Transfer) Tax Return and/or Pay Estate (and Generation-Skipping Transfer) Tax(es), that requested an extension of the due date for filing the estate tax return to August 28, 1991, 6 months after thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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