- 3 - 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 chemicallyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011