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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 the
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