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estate tax return that was provided during December 1991 and
January 1992.
Mr. Belotz completed preparation of petitioner's estate tax
return during January 1992. The return was filed on January 24,
1992, and reported an overpayment of estate tax in the amount of
$2,867.
OPINION
The only issue remaining to be decided in the instant case
is whether petitioner is liable for the addition to tax for
failure to file the estate tax return timely. Section 6018(a)
generally provides that an estate tax return shall be filed where
the gross estate at death exceeds $600,000. Section 6075(a)
provides that the return shall be filed within 9 months after the
date of a decedent's death. In the instant case, decedent died
on May 28, 1990, and the estate tax return therefore was due on
or before February 28, 1991. Sec. 20.6075-1, Estate Tax Regs.
Section 6081(a) permits the Secretary to grant a reasonable
extension of time for the filing of a return but provides that,
"Except in the case of taxpayers who are abroad, no such
extension shall be for more than 6 months." The regulations
issued with respect to section 6081(a) provide that the total
allowable extension of time for filing an estate tax return is 6
months from the original due date of the return. Sec. 20.6081-
1(a), Estate Tax Regs. The due date of petitioner's estate tax
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