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filed a Form 4768, Application for Extension of Time to File a
Return and/or Pay U.S. Estate Taxes, requesting an extension of
time to file the estate tax return until January 14, 1995, and an
extension of time to pay the estate tax until July 14, 1995. The
requested extensions were granted by the Commissioner.
The January 14, 1995 extended due date for filing the estate
tax return expired with no return having been filed. Following
respondent’s written inquiry as to the status of the estate tax
return in late May 1995, Mr. Forgey signed the return and mailed
it to the Internal Revenue Service Center in Ogden, Utah. The
Commissioner received the estate tax return on June 2, 1995. The
return reflected an estate tax liability of $2,165,565 and a
balance due of $1,683,565.4
On July 17, 1995, respondent assessed the estate tax
liability and a section 6651(a)(1) addition to tax for late
filing in the amount of $378,802.5 The addition to tax was based
on the tax reported as due on the return.
By notice of deficiency dated April 23, 1998, respondent
determined a deficiency in estate tax of $866,434. Based on this
deficiency, respondent determined an additional section
4 The estate submitted a payment of $482,000 with the Form
4768, Application for Extension of Time to File a Return and/or
Pay U.S. Estate Taxes.
5 Respondent also assessed interest and an addition to tax
for late payment under sec. 6651(a)(2). These amounts are not in
dispute.
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Last modified: May 25, 2011