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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 and
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