- 4 - $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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011