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On January 28, 1993, Christy timely filed a Form 4768,
asking that the due date for filing the estate tax return be
extended by 5 months and 27 days to July 31, 1993, and that the
due date for paying the estate tax be extended by 10 months and
27 days to December 31, 1993.
Christy attached the following statement to the Form 4768:
STATEMENT RE EXTENSION OF TIME TO FILE FORM 706
It is impossible to file a reasonably complete return by
February, 1993, because of difficultly in gathering
information necessary to identify and appraise decedent’s
real properties. It is anticipated from work already done
by counsel, probate appraisers, and title company, that
appraisals will be done and an accurate return filed by July
1, 1993.
The estate’s real properties appear to consist of 7 parcels
[see supra note 4] in Santa Clara County, California.
Deferred maintenance and hidden defects affecting market
value need to be explored.
On February 11, 1993, respondent approved a 6-month
extension for filing, to August 4, 1993, and a 1-year extension
for paying, to February 4, 1994. Table 1 shows the original due
dates, the extended due dates requested by Christy, and the
extended due dates approved by respondent.
Table 1
Original Requested Approved
Tax return due date 02/04/93 07/31/93 08/04/93
Payment due date 02/04/93 12/31/93 02/04/94
On the Form 4768 Christy had caused to be typed in the
“Extension date requested” boxes of part II (extension for
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