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By letter dated March 30, 1994, and addressed to Hinz at his
home address, respondent tentatively allowed petitioner’s section
6166 election. This letter states that there is a balance due of
$507,914.99 ($220,402.67 for nondeferred tax, and the remainder
for interest and penalties), which is to be paid by April 25,
1994.
By letter dated February 6, 1995, and addressed to Hinz at
his home address, respondent states that petitioner did not meet
the requirements of section 6166 because the estate tax return
was not filed timely. This letter states that there is a balance
due of $5,297,476.68 ($3,500,270.19 for tax, and the remainder
for interest and penalties), which is to be paid by February 27,
1995.
By letter dated March 8, 1995, respondent informed Christy
that decedent’s estate tax return was being examined. This
letter asks Christy to send numerous records of the estate to
respondent. Sometime after Christy received the March 8, 1995,
letter, the agent who was conducting the examination of
decedent’s estate tax return told Christy that decedent’s estate
tax return was filed late. Notwithstanding the February 6, 1995,
letter to Hinz, this was the first time that Christy learned that
decedent’s estate tax return may have been filed late. At the
suggestion of this agent, on November 25, 1996, Christy wrote a
letter to the District Director explaining that because Christy’s
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