Estate of Glenn G. Forgey - Page 4




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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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