Estate of Delores E. Lasarzig, Deceased, Wells Fargo Bank, Trustee - Page 3




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          Background                                                                  
               Delores E. Lasarzig (decedent) died on March 14, 1993, and             
          her gross estate primarily consisted of interests in two trusts.            
          One trust was decedent’s living trust, and the other was a                  
          qualified terminal interest property (QTIP) trust established               
          under decedent’s predeceased husband’s will.  Other than the two            
          trusts, decedent’s sole assets were those that had been in her              
          conservatorship estate prior to death.  The estate was granted a            
          6-month extension to June 14, 1994, for payment of the Federal              
          estate tax.  The estate had paid $500,000 with the first request            
          for extension and estimated that a $3,151,785 estate tax was due.           
          Because the estate had a $2,735,537 cash shortfall, a second                
          extension was requested, and, at the time of the request, another           
          $416,248 in tax plus $14,784 interest was paid.  By means of an             
          October 13, 1994, letter, respondent denied the estate’s request            
          for a second extension.                                                     
               The estate administratively appealed respondent’s denial,              
          explaining that the estate involved two trusts, a family trust              
          and a QTIP testamentary trust established under decedent’s late             
          husband’s will.  The family trust had paid its portion of the               
          estate tax, but the QTIP trust was unable to pay currently its              
          remaining share ($2,700,275).  The QTIP trust had sold all of its           
          assets with the exception of three parcels of realty.  One                  
          property, an automobile service station, was chemically                     





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