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of time for payment of its estate tax liability until September
1991; on October 19, 1990, this request was denied. Because the
estate defaulted on its installment agreement, its section 6166
election was terminated as of October 19, 1990.
As of June 9, 2000, the estate had paid $129,990.47 of its
estate tax liability. (On September 21, 1982, the estate remitted
$12,426.07 with its original Form 706, and on August 14, 1992, the
estate remitted $117,564.40.) The estate paid $2,289,770.55 in
interest.
On April 22, 1996, respondent filed a Motion for Entry of
Decision in docket No. 42224-85; on September 6, 1996, this Court
granted respondent’s motion and entered a decision reflecting a
$3,835,638.40 unpaid estate tax liability. (The September 6, 1996,
decision was not appealed.)
On May 28, 1993, the estate filed an offer in compromise
regarding its estate tax liabilities; on October 27, 1994,
respondent rejected the offer. On April 9, 1996, the estate filed
a second offer in compromise; on June 27, 1996, respondent
rejected this offer.
West Lakeland Land Co., Inc.
The major asset of the estate was a 100-percent stock
ownership of West Lakeland Land Co., Inc. (WLLC), a land
development S corporation. Anthony Fridovich was president of WLLC
from 1984 until 1995, when the company was liquidated. On May 31,
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