Estate of Donny David Doster - Page 2




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          section 61611 extension request was an abuse of discretion; (2)             
          respondent’s denial of the estate’s request for abatement of a              
          section 6651(a)(2) addition to tax for failure to pay was an                
          abuse of discretion; and (3) respondent’s determination                     
          sustaining the proposed collection action was an abuse of                   
          discretion.                                                                 
                                     Background                                       
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  When the petition was filed, petitioner’s                        
          representative, Jimmy Mack Doster, Independent Executor                     
          (executor), resided in Sulphur Springs, Texas.  At the time of              
          his death, Donny David Doster was domiciled in Texas.                       
               On February 5, 1997, Donny Doster and his wife, Judy Doster,           
          won a $35.3 million Texas lottery jackpot (Lotto), payable in 20            
          annual installments of $1,768,000.  On March 15, 1997, the                  
          Dosters formed Texas East-West Limited Partnership to collect and           
          invest the Lotto proceeds.  Mr. and Mrs. Doster each received a             
          2-percent general partnership interest and a 48-percent limited             
          partnership interest.                                                       


               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  






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Last modified: May 25, 2011