- 3 - the estate, the trust, or petitioner; and (2) whether a section 6651(a) addition to tax for failure to timely file a tax return is applicable. All section references are to the Internal Revenue Code in effect for the year under consideration. All Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts are rounded. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Background Petitioner resided in Springfield, Virginia, on the date her petition was filed. The legal address of both the trust and the estate was in Springfield, Virginia, at the time they petitioned this Court. Decedent and Her Estate Edna B. Hunter’s (decedent’s) only child, Herbert C. Hunter (Mr. Hunter), was married to Shirley M. Hunter (Mrs. Hunter). Mr. and Mrs. Hunter had a daughter, petitioner, who was born on November 3, 1968. Mr. Hunter was murdered in 1976. On April 11, 1984, decedent died intestate, leaving an estate valued at over $20 million to petitioner. Mrs. Hunter qualified and served as the administratrix of decedent’s estate. Mrs. HunterPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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