Edith Hunter Hornberger, et al. - Page 3




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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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