Estate of Helen G. Williamson, Deceased, Douglas F. Woods, Executor - Page 5

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          returnable in decedent's Federal estate tax return.  Pursuant to            
          the extension of time granted, the Federal estate tax return was            
          timely filed on September 30, 1988.  Attached to that return was            
          a copy of the request for extension of time originally made, and            
          that request contained an explanation and justification for                 
          granting the extension of time.  At the time the return was                 
          filed, the controversy between decedent's estate and decedent's             
          surviving husband still continued and was not settled until at              
          least January 14, 1991.  As a result, the estate tax return that            
          was filed herein did not include a large volume of assets, which            
          was one subject of respondent's deficiency notice herein.                   
               Exactly when respondent became aware of the quantity and               
          value of the assets that had been omitted from petitioner's                 
          Federal estate tax return is unclear in this record.  However, on           
          September 21, 1994, more than 3 years after the return was filed,           
          but less than 6 years thereafter, respondent issued the statutory           
          notice of deficiency that has been contested herein.  There is no           
          evidence that any amended estate tax return was filed by                    
          petitioner.                                                                 
               In the controversy between petitioner and respondent, both             
          at the administrative level and in the proceeding before this               
          Court, respondent took the position that, since the omission of             
          assets from the return as filed was in excess of 25 percent of              
          the gross estate, the applicable period of limitations was                  






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