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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. Hunter
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