- 17 - 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 fiduciariesPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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