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For each year of the estate's administration,
Mr. de St. Aubin's estate has filed a United States
Fiduciary Income Tax Return, Form 1041. The Internal
Revenue Service requested that his executors justify the
continued existence of the estate as a taxpayer for the tax
years ending October 31, 1981, and October 31, 1982. The
executors submitted responses, and the Internal Revenue
Service did not further contest the estate's right to
continued existence as a taxpayer for income tax purposes.
Decedent's executors filed her United States Estate
Tax Return, Form 706, with the Internal Revenue Service on
September 27, 1984. Thereafter, respondent issued a notice
of deficiency to the executors of decedent's estate
asserting a deficiency in Federal estate tax in the amount
of $20,607,275.29. Corinne Shaw and Ovide E. de St. Aubin,
acting in their capacity as executors, filed a petition
with this Court to dispute the entire amount of the
deficiency.
Subsequently, respondent determined that, as
fiduciaries, Ovide E. de St. Aubin and Corinne Shaw are
each personally liable for the entire estate tax
deficiency. Accordingly, respondent issued notices of
deficiency to Ovide E. de St. Aubin and Corinne Shaw for
Federal estate tax due from the estate as fiduciaries
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