Estate of Mary K. Wetherington, Deceased, Mary Louise Ripple, Personal Representative - Page 8

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          Respondent has previously granted an extension under section                 
          6161(a).  According to our record, petitioner's request for a                
          further extension is now pending.                                            
               Respondent contends that we should not delay entry of                   
          decision because it would enable petitioner to deduct interest               
          that it could not otherwise deduct.  We disagree with                        
          respondent's view that such a result is improper.  Section                   
          6161(a), like section 6166, can result in an extension of time               
          for a taxpayer to pay estate tax.  We believe the situation in               
          this case is analogous to that in Estate of Bailly v.                        
          Commissioner, supra.                                                         
               We distinguish this case from Estate of Nevelson v.                     
          Commissioner, T.C. Memo. 1996-361, because there petitioners                 
          asked the Court to delay entry of decision more than 5 years past            
          the date the parties had agreed to file a stipulated decision.               
          Here, the parties have not agreed to a date to file a stipulated             
          decision.                                                                    
               2.   Whether Granting Petitioner's Motion Would Interfere               
                    With Respondent's Exercise of Discretion Under Section             
                    6161                                                               
               Section 6161(a) gives the Commissioner discretion to grant a            
          taxpayer's request for extension of time to pay taxes.                       
          Respondent contends that granting petitioner's motion would                  
          eliminate that discretion.  We disagree.  Our granting of this               







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