- 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
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