- 5 - and State Governments estate tax, and Ms. Midgorden wrote checks to the Commissioner and to the Minnesota Department of Revenue for the "decided" amounts. The check to the Commissioner, which was in the amount of $225,400, was hand delivered to the Internal Revenue Service (the Service) later that day. Mr. Weinberg completed the decedent's Federal estate tax return in early May 1995, and Mr. Weinberg forwarded the return to Ms. Midgorden at or about the same time. On May 9, 1995, Ms. Midgorden signed the return, in her capacity as personal representative, and, on the next day, she mailed the return to the Commissioner. The Commissioner received the return on May 12, 1995. The return reported that the value of the decedent's taxable estate equaled $1,499,403, and that the estate's tax liability was $298,381. Enclosed with the return was a check for the balance due (with interest), and a letter from Ms. Midgorden stating in part: I, as personal representative of the estate, would ask that any penalty which would otherwise be imposed be waived by the IRS for the following reasons: Immediately upon the death of Mr. Nemerov and my appointment as personal representative of the estate, I retained an accountant to handle all tax matters for the estate, since I have no knowledge of tax laws for estates and am only a long-standing friend of the decedent, not a tax accountant. The accountant I retained had been the accountant of the decedent for many years. The accountant became ill and turned over the handling of the estate to a new accountant. For some reason, the old accountant told the new accountant that the return was being handled by an attorney andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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