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to pay the estate tax to March 28, 1992. On April 4, 1991,
respondent denied petitioner's application for extension of time
to file, but approved the application for extension to pay. On
September 6, 1991, petitioner filed the estate's Form 706, United
States Estate (and Generation-Skipping Transfer) Tax Return.
Wang, a certified public accountant, helped in petitioner's
filing of the return.
At the time of decedent's death, decedent and Yang owned the
following five real properties (collectively the Young Property),
each of which they had acquired by deed as husband and wife, as
joint tenants: (1) The Bixby Knolls Motel, located at 4045 Long
Beach Boulevard in Long Beach, California, which was purchased by
decedent and Yang on May 19, 1983; (2) a condominium located at
111 North Moore Avenue, #A, in Monterey Park, California, which
was purchased by decedent and Yang on February 18, 1986; (3) the
Oak Tree Inn located at 788 West Huntington Drive in Monrovia,
California, which was purchased by decedent and Yang on August
25, 1987; (4) a condominium located at 3507 Birkdale in El Monte,
California, which was purchased by decedent and Yang on September
2, 1988; and (5) a house located at 1635 Vallecito Drive in
Hacienda Heights, California, which was purchased by decedent and
Yang on March 13, 1989. At no time prior to decedent's death did
decedent or Yang execute a writing to change their legal title,
as husband and wife as joint tenants, in the properties.
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