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initial due date, and estimated the estate's Federal estate tax
liability as $50,184. Mr. Belotz transmitted the extension
application form to Mr. Blum, who in turn sent it to Mr.
Constantino. Mr. Constantino signed the form, which was dated
February 6, 1991, and mailed it to the Internal Revenue Service
(Service) on February 21, 1991, which received it on February 23,
1991. Because Mr. Constantino did not have sufficient probate
assets to pay the estimated estate tax due, funds subject to the
guardianship proceeding were used for that purpose.
On April 29, 1991, the Service approved the requested
extension of the due date for filing the estate tax return, and
Mr. Belotz informed Mr. Constantino that the due date, as
extended, was August 28, 1991 (the extended due date).
The following inventories and appraisals of assets were
filed with the superior court in connection with the guardianship
proceeding on the dates shown:
Inventory Date Appraisal
Partial No. 1 Apr. 15, 1991 $573,283.98
Complete and Final May 28, 1991 41,724.53
Supplemental June 17, 1991 96,630.99
Supplemental # 2 July 31, 1991 104,645.00
Supplemental # 3 Nov. 18, 1991 3,152.58
Supplemental # 4 Apr. 14, 1992 11,984.64
Mr. Blum provided Mr. Belotz with a copy of each of those
inventories shortly after the respective inventory was filed with
the superior court. Mr. Blum also provided such information to
Mr. Constantino.
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