Estate of Delores E. Lasarzig, Deceased, Wells Fargo Bank, Trustee - Page 4




                                        - 4 -                                         

          contaminated, affecting its marketability.  The other two                   
          properties had been leased to a third party who had developed               
          them into a shopping center.  It appears that the shopping center           
          properties were the most significant assets held in the QTIP                
          trust and the only potential source for the payment of the QTIP’s           
          agreed portion of the estate tax liability.  The estate explained           
          to respondent that because of a depressed real estate market and            
          for various other reasons these properties were not expected to             
          “bring a very good price” at that time.  On November 15, 1994,              
          respondent approved a second extension to June 14, 1995.                    
               Thereafter, on September 27, 1995, the QTIP trustee                    
          distributed the two shopping center parcels to decedent’s                   
          beneficiaries as tenants in common, who in turn transferred the             
          property to the beneficiaries’ respective personal family trusts.           
          The trustees of the personal family trusts and the beneficiaries            
          of decedent’s estate are the same persons (the children of                  
          decedent).  The personal family trust of each beneficiary was               
          separate from the two trusts that made up the bulk of the                   
          estate’s assets.  The estate’s request for a third extension was            
          filed and denied during 1995, and in the appeal it was explained            
          that the service station was under contract whereby it would be             
          sold, and the transaction was expected to close in about 60 days.           
          Respondent granted the third extension until June 14, 1996.                 







Page:  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