Estate of Mary K. Wetherington, Deceased, Mary Louise Ripple, Personal Representative - Page 3

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               Section references are to the Internal Revenue Code as                  
          amended.  Rule references are to the Tax Court Rules of Practice             
          and Procedure.                                                               
                                      Background                                       
               Mary K. Wetherington (decedent) died on April 8, 1990.  Her             
          estate consisted almost exclusively of agricultural real property            
          in Hillsborough County, Florida.  Petitioner filed decedent's                
          estate tax return on September 9, 1991.  Petitioner paid Federal             
          estate tax of $61,000 on April 2, 1991, and $97,793.77 on August             
          18, 1992.                                                                    
               On March 3, 1995, petitioner sold part of decedent's real               
          property.  Petitioner paid estate taxes of $498,321.93 on March              
          6, 1995.                                                                     
               Under section 6161(a)(1), the Secretary may extend the time             
          in which a taxpayer must pay estate tax for up to 12 months.                 
          Under section 6161(a)(2), the Secretary may grant an extension,              
          for reasonable cause, up to 10 years from the due date of the                
          return.                                                                      
               Respondent extended the time for petitioner to pay estate               
          tax under section 6161(a) for 1 year, and possibly for a second              
          year, because petitioner's assets were not liquid, and petitioner            
          could not pay the balance due.  Petitioner applied for a further             
          extension under section 6161(a), which is pending as of December             
          18, 1996.                                                                    





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