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$10,925,101.10 total unpaid estate tax liability of the estate),
unless the statute of limitations or the doctrine of laches bars
the assessment of this liability. Thus, following concessions by
both parties, the issue to be decided is whether the statute of
limitations (or alternatively, the doctrine of laches) bars
respondent from assessment and collection of the $1,118,621
transferee liability against petitioner.
The stipulation of facts and the attached exhibits are
incorporated herein. The stipulated facts are hereby found.
At the time the petition was filed, petitioner resided in Fort
Lauderdale, Florida.
Background
On December 4, 1981, Martin Fridovich died testate.
Petitioner served as personal representative of the estate until
June 11, 1984, when he was replaced by his brother, Anthony
Fridovich.
The Estate Tax Return
On September 21, 1982, the estate filed a Form 706, U.S.
Estate Tax Return, reflecting $3,883,147.43 in tax due; it paid
$12,426.07. Pursuant to section 6166, the estate elected to defer
payment of the balance ($3,870,721.36) for 5 years and to
thereafter pay the balance in 10 annual installments of $387,072.14
each.
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