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Estate of Fridovich v. Commissioner, Docket No. 42224-85
On August 26, 1985, respondent mailed a notice of deficiency
to the estate, determining that the estate owed an additional
$7,122,367 in estate tax. Thereafter, on November 21, 1985, the
estate commenced a case in this Court contesting respondent’s
determinations, which case was assigned docket No. 42224-85 (docket
No. 42224-85), Estate of Fridovich v. Commissioner. That case was
set to be heard on November 28, 1988. The case settled, and on
November 28, 1988, the following documents were filed and
respective actions taken: (1) Pursuant to a joint stipulation, a
$2,778,327.92 interim assessment was authorized; (2) this Court
granted the parties’ Motion to Stay Further Proceedings, postponing
entry of decision until the final installment of tax was due or
paid (whichever occurred earlier); and (3) the estate and
respondent entered into a closing agreement (agreeing that a
certain Cayman Islands Trust created by Martin Fridovich was a sham
for income, gift, and estate tax purposes, and that the estate
would be considered the actual owner of the Trust’s assets for
income, estate, and gift tax purposes).
The estate did not pay any of the required estate tax
installments (pursuant to its section 6166 election) but instead
requested extensions of time with respect to the tax installments
due for 1987, 1988, and 1989. The requests for extensions were
granted. In August 1990, the estate requested a further extension
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