- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011